Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Appellants' motion to intervene in this wrongful death action, holding that heirs of the decedent cannot intervene in a wrongful death action brought by the wrongful death representative.Carrie Linn died after undergoing elective surgery. Carrie's niece, Kallista Mills, was appointed Carrie's wrongful death representative. Mills brought this wrongful death action against Charles Linn, Carrie's husband, alleging that he had negligently caused Carrie's death. One year later, Mills signed a release releasing Charles from all causes asserted against him. Mills and Charles then filed a stipulated motion to dismiss the wrongful death action with prejudice. After the execution of the release but before the filing of the stipulated motion to dismiss, Appellants - Carrie's daughters - filed a motion to intervene in the wrongful death action. Because Appellants did not timely serve counsel the motion, the court dismissed the action with prejudice. The Supreme Court affirmed, holding that beneficiaries, unless appointed as the wrongful death representative, are precluded from intervening in wrongful death actions. View "Archer v. Mills" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment to Defendants and dismissing Plaintiff's claims for negligent misrepresentation and intentional interference with a contract, holding that Defendants were entitled to summary judgment.Plaintiff sued Defendants, her adult stepchildren, claiming that they caused their father - and Plaintiff's late husband - to remove Plaintiff as the primary beneficiary of his insurance plan. The district court determined that Plaintiff failed to present evidence to establish any genuine dispute of material fact for trial and awarded summary judgment for Defendants. The Supreme Court affirmed, holding that summary judgment was proper because Plaintiff failed to establish a dispute of material fact as to whether Defendants supplied false information and as to whether a valid contract existed between her and Defendants. View "Page v. Meyers" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Plaintiff's motion to amend and dismissing her survival action against Westview Health Care Center for injuries her deceased father received while in Westview's care, holding that the district court erred in dismissing Plaintiff's survival action.After Plaintiff filed her complaint, she moved to amend the complaint to add a wrongful death claim. The district court denied the motion to amend and dismissed the survival action on the grounds that Plaintiff was not the real party in interest. The Supreme Court reversed in part, holding (1) the district court did not abuse its discretion by denying Plaintiff's motion to amend because the wrongful death claim was barred by a two-year condition precedent; and (2) because Westview's motion was untimely, the court erred in dismissing Plaintiff's survival action on the grounds that she was not the real party in interest. View "Gaston v. Life Care Centers of America, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's Wyo. R. App. P. 21 motion asserting that his trial counsel provided ineffective assistance when he failed to raise a challenge under Batson v. Kentucky, 476 U.S. 79 (1986), holding that the district court did not err.Defendant was convicted of conspiracy to commit aggravated robbery. During trial, the State used two peremptory challenge to strike the only minority jurors in the venire. Defendant's counsel failed to raise a Batson challenge to the State's use of peremptory challenges. The Supreme Court affirmed, holding (1) there is no direct appeal of a Batson claim if it was not raised in the trial court; (2) the failure to raise a Batson challenge is not usually structural error when it is brought in the context of an ineffective assistance of counsel claim; (3) the district court correctly ruled that trial counsel was not ineffective for failing to raise a Batson challenge; and (4) the district court had not duty sua sponte to raise Batson on its own under the facts of this case. View "Yazzie v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court deciding that Plaintiffs failed to establish the elements required to establish an implied easement, holding that the district court did not err.Plaintiffs sued Defendant, their neighbor, for quiet title and a declaratory judgment that they had an implied easement across Defendant's property for commercial recreational activities. The district court concluded that Plaintiffs did not have an implied easement across Defendant's property because they failed to carry their burden to prove the claimed easement was necessary and beneficial to the enjoyment of their property. The Supreme Court affirmed, holding that the district court (1) applied the correct "necessity" standard to establish an implied easement; and (2) did not find that Defendant was a bona fide purchaser entitled to statutory and common law protections. View "Wheeldon v. Elk Feed Grounds House, LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court awarding Father custody of the parties' minor child subject to Mother's visitation, holding that the district court did not abuse its discretion when it dismissed Mother's motion for an order to show cause.Upon the parties' divorce, the district court awarded Father custody of the parties' child subject to Mother's specified visitation. After Father and the child moved to Bahrain, Mother, who lived in Russia, filed a petition to modify custody and visitation. Mother filed a motion for an order to show cause. The district court dismissed the show cause motion and granted Father's modification petition, applying the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA) and the common law doctrine of forum non conveniens. The Supreme Court affirmed, holding that the district court did not err in dismissing Mother's show cause motion for inconvenient forum under the UCCJEA. View "Pokrovskaya v. Genderen" on Justia Law

The Supreme Court reversed the decision of the district court denying KA's unopposed petition for adoption of minor child under Wyo. Stat. Ann. 1-22-101 et seq., holding that the adoption statutes did not prohibit KA from adopting the child.KA sought to adopt his ex-wife's son, with whom he had a loving relationship. Until recently, the child believed KA was his biological father, and when he learned the truth, he requested that KA adopt him. KA filed an unopposed petition to adopt the child. The district court denied the petition on the grounds that KA was married and thus not a "single adult," he did not jointly filed to adopt the child with his current wife, and his current wife was not the child's mother. The Supreme Court reversed and remanded the case for further proceedings, holding that that the adoption statutes did not prohibit KA from adopting the child. View "In re Adoption of ATWS" on Justia Law

The Supreme Court affirmed the judgment of the district court setting aside an investigative subpoena served by the Consumer Protection Unit of the Wyoming Office of Attorney General, holding that there was no error or abuse of discretion.WyoLaw, LLC filed this petition to set aside the Attorney General's subpoena, claiming that it was not subject to the Attorney General's investigative authority, that the Attorney General lacked probable cause to support its subpoena, and that the documents were protected by the work product doctrine and the attorney client privilege. The district court denied the request to modify or set aside the subpoena and ordered WyoLaw to produce the documents. The Supreme Court affirmed, holding that the district court did not abuse its discretion. View "WyoLaw, LLC v. State, Office of the Attorney General, Consumer Protection Unit" on Justia Law

In this eminent domain dispute, the Supreme Court reversed the first order of the district court allowing EME Wyoming, LLC access to approximately 52,000 acres of land located primarily in Goshen County and affirmed the second order permanently barring EME from using survey information it collected to file permits to drill (APD) with the Wyoming Oil and Gas Conservation Commission (WOGCC), holding that the district court erred in part.EME sought access to land owned by four limited liability companies (collectively, the BRW Group) for the purpose of gathering data to evaluate the property's suitability for condemnation. The BRW Group denied EME's request, believing that EME sought access to the lands solely to collect data with which to file APDs, which is not a proper purpose under the Wyoming Eminent Domain Act. The district court allowed EME to access the property to survey and gather data but restricted it from using the survey information to file APDs. The Supreme Court reversed in part, holding (1) EME should not have been permitted access to the property because it did not make the required showing for access to the BRW Group's property; and (2) therefore, the data EME collected to file APDs was not lawfully in EME's possession, and EME could not use the data for any purpose. View "BRW East, LLC v. EME Wyoming, LLC" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence obtained at the end of a traffic stop, holding that the traffic stop was unlawfully extended after its initial purpose had been resolved.Defendant entered a conditional plea to methamphetamine possession and child endangerment. Defendant appealed, arguing that the district court erred in denying his motion to suppress evidence obtained at the end of the traffic stop because the stop was unlawfully extended before a drug dog alerted. The Supreme Court agreed, holding (1) Defendant did not waive his argument that the stop was unlawfully extended; and (2) Defendant's Fourth Amendment rights were violated because the law enforcement officer unlawfully extended the duration of the traffic stop after he completed the citation. View "Mahaffy v. State" on Justia Law