Justia Wyoming Supreme Court Opinion Summaries

The appellant worked as a maintenance worker and suffered a work-related back injury in March 2022. He ceased working, reported the injury, and began receiving medical treatment, including physical therapy and medication. The Wyoming Workers’ Compensation Division recognized his injury as compensable and awarded him temporary total disability (TTD) benefits. Over the following year, the appellant continued to experience back pain, but his doctor noted improvements, and by March 2023, multiple medical professionals—his treating physician and two independent medical examiners—agreed he had reached maximum medical improvement (MMI). Based on these findings, the Division terminated his TTD benefits and awarded him permanent partial impairment (PPI) benefits.The appellant contested the Division’s determination, arguing he had not yet reached MMI and that the TTD benefits should not have been terminated. He did not present additional medical evidence to support his claim but relied on his own testimony. The Medical Commission held a contested case hearing and found, based on the medical evidence, that he had reached MMI as of March 2023. Consequently, the Medical Commission upheld the Division’s termination of TTD benefits. The appellant appealed to the District Court of Laramie County, which affirmed the Medical Commission’s decision.On further appeal, the Supreme Court of Wyoming reviewed the case as if it had come directly from the Medical Commission, without deference to the district court’s decision. The Supreme Court held that substantial evidence supported the Medical Commission’s finding that the appellant had achieved MMI as of March 2023. Therefore, the termination of TTD benefits was proper under Wyoming law, and the Supreme Court affirmed the Medical Commission’s and district court’s decisions. View "Martinez v. State of Wyoming" on Justia Law

A company sought a lease from the Wyoming Board of Land Commissioners to develop a wind energy project on state land in Converse County. This project was designed to power a green hydrogen facility, with grid connection being possible but not necessary. The applicant engaged stakeholders and amended its proposal in response to feedback, including reducing the project’s footprint and number of turbines. Public comments were received, most expressing opposition. After a public meeting and legal consultation, the Board approved the lease.Stephens Land and Livestock, LLC, which owns property adjacent to the leased state land, challenged the Board’s approval in the District Court of Converse County. Stephens argued that the lease approval was not in accordance with law, exceeded statutory authority, and violated Board rules, including a requirement that wind energy leases involve connection to the transmission grid. The district court found that Stephens had standing, concluded the Board’s rules required grid connection for wind energy leases, and reversed the lease approval.On appeal, the Supreme Court of Wyoming reviewed the Board’s decision as if it came directly from the agency. The Court held that Stephens had standing due to immediate, substantial, and pecuniary interests affected by the project. Interpreting the Board’s rules, the Court found the term “including” to be expansive, meaning grid connection is one example of a permissible use, not a requirement. The Court concluded the lease approval was in accordance with law and did not conflict with the Board’s definition of “Wind Energy Leasing.”The Court further addressed and rejected Stephens’s additional legal arguments, finding the Board complied with its statutory duties, did not violate relevant executive orders or rules, and provided adequate financial assurances. The Supreme Court of Wyoming affirmed the Board’s approval of the wind energy lease. View "Pronghorn H2, LLC v. Stephens Land and Livestock, LLC" on Justia Law

A marketing and communications specialist employed by a state university alleged that she was subjected to sex-based discrimination, was paid less than a male counterpart for equivalent work, and experienced a hostile work environment. After raising concerns about this treatment, she alleged the university retaliated against her, culminating in her termination. She further claimed that, following her dismissal, the university provided false information to the state workforce agency, which delayed her receipt of unemployment benefits.After being terminated, the employee filed a pro se complaint in the District Court of Albany County, Wyoming, asserting claims for retaliation, sex-based discrimination, hostile work environment, fraud, and intentional infliction of emotional distress, and sought both monetary and injunctive relief. The university removed the case to U.S. District Court on federal question grounds, but after the employee amended her complaint to assert only state-law claims, the federal court remanded the case to the state district court. The university then moved to dismiss, arguing governmental immunity, failure to exhaust administrative remedies, and failure to state a claim. The district court granted the motion, dismissing the case without prejudice because the employee had not exhausted her administrative remedies under the Wyoming Fair Employment Practices Act (WFEPA).The Supreme Court of Wyoming reviewed the dismissal de novo. It held that the Wyoming Governmental Claims Act barred the employee’s tort claims for monetary damages, including for fraud, intentional infliction of emotional distress, and wrongful termination in violation of public policy, but did not bar claims for injunctive relief. However, the court further determined that the wrongful termination and discrimination claims were not cognizable because the WFEPA provides an adequate statutory remedy, which requires exhaustion of administrative remedies before seeking judicial review. Because the employee had not followed the required administrative process, the court affirmed the district court’s dismissal of her complaint. View "Hinckley v. University of Wyoming" on Justia Law

A 15-year-old girl, CZ, who has cerebral palsy and learning difficulties, accused Timothy R. Christensen, a family friend, of sexually assaulting her during a visit to his home. The incident allegedly occurred when CZ was left upstairs with Mr. Christensen while other adults and children were elsewhere in the house. CZ later reported the assault to her mother, underwent a sexual assault examination, and DNA evidence consistent with Mr. Christensen was found. The police investigated, including reviewing text messages between CZ and Mr. Christensen and conducting controlled communication with him through CZ’s phone.The District Court of Sheridan County charged Mr. Christensen with two counts of second-degree sexual abuse of a minor. During trial, the court admitted prior consistent statements made by CZ to her mother, a nurse, and a detective, overruling the defense’s hearsay objections. The defense argued that these admissions were improper because there was no express or implied charge of fabrication at that stage. The court also excluded evidence about a text message CZ sent Mr. Christensen containing a pregnancy test photo, finding it inadmissible under Wyoming’s rape shield statute and lacking relevance. The jury found Mr. Christensen guilty on one count and acquitted him on the other. He was sentenced to five to eight years in prison.The Supreme Court of Wyoming reviewed whether the district court abused its discretion in admitting CZ’s prior consistent statements and in excluding the pregnancy test text message. The Supreme Court held that the prior consistent statements were properly admitted under W.R.E. 801(d)(1)(B) because the defense’s theory implied fabrication, and that the pregnancy test message was properly excluded due to lack of relevance, regardless of the rape shield statute. The conviction and rulings of the district court were affirmed. View "Christensen v. State" on Justia Law

GateOne Gillette, LLC entered into a 20-year lease with the Northeast Wyoming Regional Airport Board to serve as the fixed base operator at the Campbell County airport, providing services such as flight instruction and aircraft maintenance. The Board was responsible for maintaining certain airport facilities and for shared maintenance of the fuel farm. In March 2025, the Board issued a notice terminating GateOne’s lease, asserting breach of contract, and subsequently took over GateOne’s operations and solicited its employees.GateOne filed a lawsuit against the Board in the District Court of Campbell County, seeking declaratory relief, damages for breach of contract, breach of the implied covenant of good faith and fair dealing, and unjust enrichment. The Board moved to dismiss the suit under Rule 12(b)(6), asserting that it was immune from suit under both the terms of the lease and the Wyoming Governmental Claims Act (WGCA). The district court denied the Board’s motion, finding that the lease was ambiguous regarding the preservation of governmental immunity and could reasonably be read in more than one way. The Board appealed that denial.The Supreme Court of Wyoming first determined that the order denying the motion to dismiss based on governmental immunity was immediately appealable because immunity under the WGCA constitutes immunity from suit, not merely a defense to liability. On review, the Supreme Court held that the lease was ambiguous as to whether it preserved the Board’s immunity from contract claims, noting conflicting provisions and the need to consider extrinsic evidence. The Court affirmed the district court’s denial of the motion to dismiss and remanded for further proceedings to resolve the ambiguity using extrinsic evidence, as necessary. View "Northeast Wyoming Regional Airport Board v. GateOne Gillette, LLC" on Justia Law

A dispute arose between two parents regarding custody of their daughter, after the end of their relationship. The father, an emergency room physician living in Montana, consistently traveled to Wyoming to visit the child, while the mother, a radiological technician, resided in Wyoming. The mother was the primary caregiver for the child, but concerns were raised about her decisions regarding childcare arrangements, particularly involving her boyfriend’s criminal history and drinking. Additionally, the mother had another child from a previous relationship, whose father is a registered sex offender, and she allowed interactions between the two children. Over time, disagreements surfaced regarding visitation, schooling, and medical decisions for the daughter, culminating in both parents seeking primary custody.The District Court of Natrona County held a bench trial to determine custody. Both parents presented evidence regarding their respective abilities to care for the child, including testimony about living conditions, work schedules, and the involvement of other adults in the child’s life. The district court found that while both parents were competent, the mother’s choices regarding caregivers, as well as her actions during the proceedings (such as violating a sequestration order and redacting discovery materials), raised safety and credibility concerns. The court also considered the child’s relationship with her half brother but ultimately concluded that the father-child bond and concerns for the child’s safety outweighed sibling separation.The Supreme Court of Wyoming reviewed the case for abuse of discretion. Applying statutory and non-statutory best-interest factors, the court held that the district court did not abuse its discretion by awarding primary physical custody to the father, giving little weight to the mother’s primary caregiver status, adequately explaining sibling separation, and reasonably assessing credibility. The Supreme Court affirmed the district court’s order, granting the father primary physical custody and the mother reasonable visitation. View "Reilly v. Sullivan" on Justia Law

A 17-year-old individual was charged as an adult for the shooting death of a 15-year-old girl during a drive-by incident at a public park in Cheyenne, Wyoming. The evidence showed that the defendant was the front passenger in an SUV from which shots were fired into a group of teenagers. Investigators recovered shell casings and the fatal bullet, and testimony indicated the victim was killed by a bullet likely fired from the defendant’s position. While the defendant denied involvement and claimed no one in the SUV had a gun, multiple witnesses and forensic analysis pointed to his participation.The District Court of Laramie County denied the defendant’s motion to transfer the case to juvenile court, citing the seriousness of the offense, lack of adequate juvenile facilities, and insufficient evidence for rehabilitation within the juvenile system. At trial, the jury was instructed on both the charged offenses and lesser included offenses. The jury acquitted the defendant of first-degree murder and conspiracy but convicted him of second-degree murder. The defendant was sentenced to 25–35 years imprisonment. He subsequently filed two post-conviction motions under Wyoming Rule of Appellate Procedure 21, alleging ineffective assistance of counsel for failures at the juvenile transfer hearing, trial, and sentencing. The district court denied these motions.On consolidated appeal to the Supreme Court of Wyoming, the defendant argued sufficiency of evidence, error in jury instructions regarding transferred intent, and that Article 1, Section 10 of the Wyoming Constitution required a stricter standard for ineffective assistance claims than the federal Sixth Amendment. The Supreme Court of Wyoming affirmed the conviction and denial of post-conviction relief. The court held that the evidence was sufficient for second-degree murder, the jury instruction on transferred intent was not plainly erroneous, Article 1, Section 10 does not require a more protective prejudice standard than Strickland, and the defendant was not denied effective assistance of counsel. View "Munoz v. The State of Wyoming" on Justia Law

Mark Martinez was charged in Laramie County with failure to register as a sex offender and eluding a police officer. After being arraigned on December 23, 2024, he demanded a speedy trial. The district court set his trial within the 180-day speedy trial deadline required by Wyoming Rule of Criminal Procedure 48. Martinez subsequently changed attorneys, leading to rescheduling of his trial, but the new dates remained within the deadline. Ten days before a scheduled trial, Martinez moved for a competency evaluation, resulting in suspension of proceedings. When the court resumed proceedings, only nineteen days remained before the Rule 48 deadline. The court scheduled the trial for November 12, 2025, believing the new date complied with the Rule 48 deadline, and neither party objected.After initially declining to dismiss the charges, the District Court of Laramie County later granted Martinez’s motion to dismiss with prejudice, concluding that a violation of Rule 48 had occurred. The court reasoned, based on its reading of Osban v. State, 2019 WY 43, that because it had not entered an order justifying the continuance before the Rule 48 deadline expired, it could not retroactively justify the delay, even though it believed the circumstances warranted a continuance in the due administration of justice. The State of Wyoming then filed a Bill of Exceptions, seeking review by the Supreme Court.The Supreme Court of Wyoming held that the district court erred in dismissing the charges. The court found Osban v. State distinguishable, concluding that Martinez had adequate notice of the trial’s rescheduling and that the continuance was required in the due administration of justice, especially since only nineteen days remained after proceedings resumed. The court emphasized that no substantial prejudice to Martinez occurred and that explicit findings of “due administration of justice” are not required. The Supreme Court sustained the State’s Bill of Exceptions, reversing the district court’s dismissal. View "The State of Wyoming v. Martinez" on Justia Law

A hunter discovered human remains in Park County, Wyoming, later identified as Angela Elizondo. Joseph Underwood, a person of interest, was apprehended after attempting to flee law enforcement and holding a handgun during a standoff. Underwood was initially charged in both Park and Laramie Counties for offenses related to the death, including concealing a felony, firearm possession, interference with an officer, fleeing police, and more serious charges in Laramie County. Extensive evaluations determined Underwood had a mild neurocognitive disorder, impairing his ability to participate in legal proceedings but potentially manageable with accommodations.After the Laramie County District Court dismissed charges due to permanent incompetency, Park County refiled charges. The Park County Circuit Court conducted further competency evaluations, some finding Underwood competent if reasonable accommodations were provided, such as slowing proceedings and using plain language. Underwood requested specific accommodations under the Americans with Disabilities Act (ADA), including an informed assistant, but this was denied by the Wyoming Judicial Branch as not mandated by the ADA. The circuit court bound the case over to the Park County District Court, which adopted the circuit court’s competency findings and proceeded with arraignment and plea hearings. During these proceedings, accommodations such as breaks, plain language, and opportunities to confer with counsel were implemented.On appeal to the Supreme Court of Wyoming, Underwood argued his Alford pleas were involuntary due to the district court’s failure to provide an informed assistant or specific accommodations for his intellectual disability. Applying plain error review, the Supreme Court of Wyoming found no clear mandate requiring an informed assistant and concluded the district court implemented approved ADA accommodations and provided ample opportunities for Underwood to understand and consult with counsel. The Court held that, under the totality of circumstances, Underwood’s pleas were knowing and voluntary and affirmed the district court’s acceptance of the pleas and imposition of sentence. View "Underwood v. The State of Wyoming" on Justia Law

The case arose after the Wyoming Legislature amended the election code to require voters who wished to change their party affiliation before a primary election to do so at least 96 days prior to the primary. Several individuals were affected by this new deadline: some were unable to vote for their preferred candidates in the 2024 primary because they could not change party affiliation after the cutoff, while others, who ran for office, were unsuccessful in their respective primaries. The plaintiffs challenged the constitutionality of the 96-day party affiliation deadline, arguing it violated their rights under the Wyoming Constitution to open, free, and equal elections, untrammeled exercise of suffrage, and equal political rights.The District Court of Laramie County granted summary judgment in favor of the Secretary of State, holding that the statutes establishing the 96-day party affiliation deadline were a valid exercise of legislative authority to regulate elections and did not violate constitutional voting rights or equal protection. The plaintiffs appealed only the district court’s ruling on the party affiliation deadline.The Supreme Court of Wyoming reviewed the case de novo, considering only legal questions as the facts were stipulated. The Court held that the right to vote in Wyoming, including in primary elections, is fundamental, but that the legislature is also constitutionally charged with securing the purity of elections. Employing a balancing approach informed by the Anderson-Burdick standard, the Court found the 96-day deadline imposed only a slight burden on voting rights, justified by the state’s legitimate interest in preventing party raiding and ensuring orderly elections. The Court further held that the deadline did not violate equal protection, as all electors had an equal opportunity to affiliate before the cutoff, and distinctions drawn between new registrants and previously registered voters were not constitutionally impermissible. The Supreme Court of Wyoming affirmed the district court’s judgment. View "Malcom v. Gray" on Justia Law