Justia Wyoming Supreme Court Opinion Summaries

A man and a woman began a relationship in 2015 and had a child in 2018. Though they were never married, they lived together until 2024. After their separation, they informally shared custody of their child, alternating time with her. In 2025, the mother unilaterally moved to Colorado with the child, initially telling the father it was a temporary visit but intending to relocate permanently. The father responded by filing for custody, visitation, and child support, and sought emergency temporary custody due to the mother’s relocation. Both parents accused each other of substance abuse but drug tests were negative.The District Court of Park County held hearings and initially awarded temporary physical custody to the mother and joint legal custody to both parents, with regular drug testing and structured visitation for the father. At a subsequent bench trial, the court continued physical custody with the mother pending a final order. Ultimately, in its final order, the court found both parents fit and competent, but awarded the mother primary physical custody, citing the child’s enrollment in school in Colorado and the stability of the mother’s home as serving the child’s best interests. The father was granted substantial visitation, including four consecutive nights each month, alternating holidays, and eight weeks each summer. The court declined to award child support to either party because of the father’s travel costs.On appeal, the Supreme Court of the State of Wyoming reviewed the district court’s custody order for abuse of discretion. The Supreme Court affirmed the district court’s decision, holding that the district court did not abuse its discretion in awarding the mother primary physical custody. The Supreme Court found the district court’s findings were supported by the record and that its decision reasonably balanced the child’s best interests and the practical challenges posed by the parents’ geographic separation. View "Swindler v. Bright" on Justia Law

Paul Sorum and Jeff Martinson, as co-owners of Clean Crude, entered into written lease agreements with Big Sky Limited of Wyoming for the rental of several aboveground oil storage tanks. After Clean Crude failed to make required lease payments and left the tanks in poor condition, Big Sky sued Clean Crude, Sorum, and Martinson, seeking damages for breach of contract and related claims. Martinson ultimately settled, and Mike Sikorski, having acquired Big Sky’s interest, was substituted as plaintiff. During a bench trial, Sikorski testified that Sorum and Martinson personally guaranteed payment of the leases if Clean Crude could not pay, but Sorum was not allowed to testify about the alleged oral guarantee.The District Court of Campbell County found Clean Crude liable for breach of the lease agreements and found Sorum personally liable for damages based on the oral guarantee. The court initially awarded damages, but Sorum appealed, and the Wyoming Supreme Court, in Sorum v. Sikorski, 2024 WY 124, reversed in part and remanded solely to allow Sorum to testify regarding the alleged oral guarantee. On remand, the district court restricted evidence to the issue of the oral guarantee, allowed Sorum to testify, and reaffirmed its finding that Sorum had made and breached a personal oral guarantee, awarding the same damages.The Supreme Court of Wyoming reviewed the district court’s actions on remand, holding that the district court properly limited the scope of evidence to the oral guarantee, consistent with the mandate rule and law of the case doctrine. The Supreme Court further held that the district court did not clearly err in finding that Sorum made an enforceable oral guarantee to pay the leases with personal funds and breached that guarantee. The Supreme Court affirmed the district court’s judgment in its entirety. View "Sorum v. Sikorski" on Justia Law

Several years after a car accident in January 2015, Samantha Ritter brought a lawsuit against William Lopez for damages. Ritter attempted to serve Lopez at the address listed in the accident report, but the Campbell County Sheriff’s Office determined that the property was vacant and could not locate him. Ritter then pursued substituted service under Wyoming’s nonresident motorist statute, which involved serving the Secretary of State and mailing the summons and complaint to Lopez’s last known address. Despite multiple efforts—including contacting his insurer, making phone calls, and hiring a search service—Ritter was unable to find a current address for Lopez.After Lopez failed to respond, Ritter sought and was granted default judgment in the District Court of Campbell County. The case was later dismissed without prejudice for failure to prosecute, but the district court reinstated the matter upon Ritter’s motion under Wyoming Rule of Civil Procedure 60. After a hearing, the district court entered default judgment in Ritter’s favor and awarded her damages. Lopez’s subsequent Rule 60 motion to set aside the default judgment was denied, and he appealed.The Supreme Court of the State of Wyoming held that Lopez waived his challenge to the sufficiency of service and due process on appeal because he had not raised those issues below, except for the jurisdictional question of due diligence required for substituted service. The court found that Ritter had exercised sufficient due diligence to serve Lopez under the statute and that personal jurisdiction was properly established. The court also determined it lacked jurisdiction to review the reinstatement of the case because Lopez’s notice of appeal did not specify that order. Finally, the court concluded that the district court did not abuse its discretion in denying Lopez’s Rule 60 motion. The decision was affirmed. View "Lopez v. Ritter" on Justia Law

The appellant and the victim were involved in a long-term romantic relationship that had deteriorated before the incident. On May 24, 2023, the two met at a convenience store in Rock Springs, Wyoming, to exchange personal items. An argument ensued and escalated, moving across several locations. The appellant maintained that after the victim threw a motorcycle part through her vehicle’s rear window, she tried to drive away and struck him unintentionally as he ran in front of her vehicle. She then transported him to a hospital, where he later died from his injuries. Initially charged with involuntary manslaughter, the charges were amended to include second-degree murder and aggravated vehicular homicide based on further investigation.The District Court of Sweetwater County presided over a four-day jury trial, during which the State presented evidence including the appellant’s statements to law enforcement, surveillance footage, accident reconstruction testimony, and communications showing a deteriorating relationship. The appellant was found guilty of second-degree murder and sentenced to forty-five years to life. After sentencing, she filed a motion for a new trial under Rule 21 of the Wyoming Rules of Appellate Procedure, claiming ineffective assistance of counsel based on several alleged failures by her trial attorney. The district court denied the motion without holding a hearing, concluding she had not shown either deficient performance or prejudice.The Supreme Court of the State of Wyoming reviewed the case. Applying the two-prong test from Strickland v. Washington, the court held that, even assuming counsel’s performance was deficient, the appellant could not establish prejudice because substantial independent evidence supported the jury’s verdict. The court found that the outcome of the trial would not have been different even if the challenged evidence had been excluded. Thus, the Supreme Court of Wyoming affirmed the district court’s denial of the motion for a new trial. View "Daniels v. State" on Justia Law

A married couple separated after the husband made a substantial prepayment to the IRS for their 2021 tax liability. Both parties subsequently filed separate tax returns for that year, and the tax preparer allocated the prepayment to the wife’s return. While the divorce proceedings were ongoing, the husband sought a court order to reallocate the prepayment. In February 2023, the District Court of Campbell County ordered the parties to file an amended joint tax return for 2021 and held them jointly and severally liable for any tax assessments related to that return. Despite this order, the couple’s tax preparer filed both a joint return and an amended individual return for the husband on the same day, which led to confusion and complications with the IRS regarding the prepayment.Following the entry of the divorce decree, which incorporated the court’s prior directives, the wife moved for an order to show cause, alleging the husband had not complied with the requirement to file a joint return. An evidentiary hearing was held, during which the court found the husband’s testimony regarding his conduct not credible and determined he had willfully frustrated the completion of the joint return by filing an amended individual return. The court ordered the husband to withdraw all other tax returns for 2021 except the joint return and to pay penalties and interest resulting from delays.The Supreme Court of Wyoming reviewed the case, applying an abuse of discretion standard and examining whether the district court’s findings were clearly erroneous. The court affirmed the lower court’s contempt order, holding that the district court did not err in its timing determination, did not abuse its discretion in finding contempt, and did not exceed the scope of the decree by ordering withdrawal of returns or monetary sanctions. The court concluded that the husband willfully disobeyed a clear court order and failed to prove inability to comply. View "Morrison v. Hinson-Morrison" on Justia Law

The case concerns a man who was convicted by a jury of six counts of sexual exploitation of a child, one count of endangering a child, and one count of unlawful contact. The offenses involved his stepdaughter (later adopted), two friends of the stepdaughter, and his son. The defendant encouraged his stepdaughter, beginning when she was 12, to engage in sexual acts with her friends—including digital penetration and the use of sexual devices—and with her stepbrother, whom she began having sexual relations with at age 12. The defendant sent text messages instructing and encouraging such conduct, supplied sexual devices, and sent pornographic material to the minor. Law enforcement became involved after an anonymous report, and following an investigation, charges were filed.After a three-day trial in the District Court of Sweetwater County, the jury convicted the defendant on all counts. The district court imposed an aggregate sentence of 21 to 30 years in prison for the sexual exploitation convictions, followed by five years of supervised probation, and concurrent 180-day jail sentences for endangering a child and unlawful contact, to run consecutively to the exploitation sentences. The defendant appealed, challenging the sufficiency of evidence for three of the sexual exploitation counts, arguing the conduct did not meet the statutory definition of “explicit sexual conduct,” and claiming his aggregate sentence was cruelly disproportionate.The Supreme Court of the State of Wyoming held that the evidence was sufficient to support the convictions, finding that digital penetration and penetration with a sexual device constituted “explicit sexual conduct” under the relevant statute. The court also determined the jury instructions were adequate to ensure unanimity for each count. Finally, the court found the sentence was not grossly disproportionate to the gravity of the offenses and did not violate the Wyoming Constitution. The convictions and sentences were affirmed. View "Duncan v. The State of Wyoming" on Justia Law

An elderly man, Harold Anderson, was removed from his home in Glenrock, Converse County, Wyoming, and hospitalized in Casper, Natrona County, due to mental health issues. While hospitalized and unable to make decisions for himself, Mr. Anderson transferred title of his vehicle and mobile home to Goldie Beedy, who took possession of both items. The transfer documents reflected values significantly below the property’s actual worth. Around the same time, local law enforcement found Ms. Beedy at Mr. Anderson’s Glenrock home, where she claimed she would become his guardian, presenting incomplete guardianship paperwork. Shortly thereafter, the Wyoming Guardianship Corporation was appointed as Mr. Anderson’s guardian.The State charged Ms. Beedy in Converse County with exploitation of a vulnerable adult. She moved to dismiss the charge, contending that the alleged conduct occurred in Natrona County, as Mr. Anderson was hospitalized there during the relevant period. The District Court of Converse County denied the motion, and a jury convicted her. The district court sentenced Ms. Beedy to a suspended prison term with supervised probation and ordered restitution for the mobile home, vehicle, and clothing purchased for Mr. Anderson by his guardian, finding Ms. Beedy’s control of the mobile home prevented access to his clothing. Restitution for other items was denied.On appeal, the Supreme Court of the State of Wyoming held that sufficient evidence supported the jury’s finding that the exploitation occurred in Converse County, as Ms. Beedy’s acts to complete the crime—including taking possession of the property and filing title documents—occurred there. The court also found no abuse of discretion in the restitution order for clothing, as Ms. Beedy’s conduct necessitated the purchases. The Supreme Court affirmed the district court’s judgment in all respects. View "Beedy v. The State of Wyoming" on Justia Law

A police sergeant stopped an individual riding a bicycle at night because he believed the bicycle did not have a light on the front, as required by Wyoming law. Upon approaching, the officer discovered the bicycle had a light, but it was very dim. The officer explained the stop, stating the light did not appear to meet statutory requirements. The individual was arrested on an outstanding warrant, and during a search, drug paraphernalia with methamphetamine residue was found. The defendant moved to suppress the evidence, arguing the stop was invalid because the officer misinterpreted the statutory requirement and made a mistake regarding the presence of a light.The District Court of Natrona County held a hearing, at which only the initial justification for the stop was contested. The court found the officer’s mistake of fact—believing there was no light—was reasonable under the circumstances, even though the statute required the light to be visible from a certain distance, not to project light. The court denied the suppression motion. The defendant entered a conditional guilty plea, reserving the right to appeal the denial of the suppression motion. He was sentenced to probation. On appeal, the defendant raised issues about the extension of the stop and ineffective assistance of counsel.The Supreme Court of Wyoming reviewed the case, adopting the district court’s factual findings unless clearly erroneous and reviewing legal questions de novo. The Court held that the officer’s initial stop was supported by reasonable suspicion based on an objectively reasonable mistake of fact. The Court further held the defendant waived issues relating to the extension of the stop and ineffective assistance of counsel because they were not reserved in his conditional plea agreement and were not tied to the voluntariness of his plea. The judgment was affirmed. View "Glenn v. The State of Wyoming" on Justia Law

The case concerned a man who, along with his wife, fostered and adopted numerous children over more than a decade. Several of these children, as well as a foster child, later accused him of sexual abuse and physical battery. Earlier reports of abuse did not result in charges, but after renewed allegations and an investigation, he was charged with seventeen counts, including various degrees of sexual abuse of minors, battery, and child endangerment. At trial, multiple victims and witnesses testified about both the charged acts and related behaviors, such as physical punishments, “daddy tax” massages, and controlling conduct allegedly used to maintain silence and compliance among the children.The District Court of Natrona County handled extensive pretrial proceedings, including multiple notices by the State to introduce evidence of uncharged acts under Wyoming Rule of Evidence 404(b). The court found this evidence relevant to issues like motive, intent, course of conduct, and family dynamics, and concluded its probative value outweighed any potential prejudice. The court also instructed the jury on the proper use of this evidence. During trial, certain defense requests—such as playing the entirety of a recorded interview and cross-examining a victim about a prior unrelated falsehood—were denied.On appeal to the Supreme Court of Wyoming, the appellant challenged the district court’s evidentiary decisions and alleged prosecutorial misconduct. The Supreme Court held that the lower court did not abuse its discretion in admitting Rule 404(b) evidence, limiting cross-examination, or declining to admit the full interview without an offer of proof. The Court also found no prosecutorial misconduct in the State’s questioning, and, because no error was established, rejected the claim of cumulative error. The Supreme Court of Wyoming affirmed the district court’s judgment. View "Marler v. State" on Justia Law

The case concerns a dispute arising from an oral agreement between a homeowner and a contractor regarding the construction of a wheelchair ramp and a covered addition at the homeowner’s residence. The parties did not sign a written contract or agree to a specific price, instead communicating the project’s scope via text messages. The homeowner paid the contractor $73,000, including $30,000 for siding, but the project was plagued by construction delays, quality concerns, and code violations. Work ceased before completion, and the contractor did not deliver or install the siding. The homeowner and his wife continued living in the property, though it did not receive a final certificate of compliance.The homeowner sued in the District Court of Sweetwater County, asserting claims including breach of contract, negligence, and breach of warranty. During discovery, the homeowner failed to provide a specific calculation of damages, only indicating he would supplement disclosures later. Before trial, the contractor moved to exclude any evidence of damages not previously disclosed. The district court partially granted this motion, limiting the homeowner’s evidence to what had been disclosed. At a bench trial, the homeowner did not call his retained expert and offered only the total amount paid as the measure of damages. The district court concluded the oral contract was unenforceable due to indefinite terms and found insufficient evidence to support a damages award.On appeal, the Supreme Court of Wyoming affirmed the district court’s rulings. The Supreme Court held that, because the homeowner failed to make an offer of proof regarding excluded damages evidence, there was no basis to review the trial court’s exclusionary ruling. The court further held that the district court’s finding—that the homeowner did not prove damages by a preponderance of the evidence—was not clearly erroneous. As the damages element was not satisfied, the Supreme Court affirmed the dismissal of the claims. View "Lacher v. Case" on Justia Law