Justia Wyoming Supreme Court Opinion Summaries

Michael Isreal Robin, Sr. was convicted by a jury on multiple counts, including theft of a vehicle, possession of cocaine, property destruction, possession of methamphetamine, and possession of marijuana. The appeal focuses solely on the conviction for theft of a vehicle. Robin contends that the State of Wyoming presented insufficient evidence to prove he exercised control over the vehicle without the owner's authorization.The District Court of Laramie County held a two-day jury trial in November 2024. The State called two witnesses: the investigating officer and the vehicle's owner, Gloria Landeroz. Officer Maljian testified about the surveillance and subsequent high-speed chase that led to Robin's arrest. Landeroz testified that she had loaned the vehicle to Robin but expected it to be returned before the day of the crash. She was uncertain about the exact dates but clarified that Robin did not have permission to use the vehicle on the day of the incident. Robin's motion for a judgment of acquittal was denied by the district court, and the jury found him guilty of vehicle theft.The Supreme Court of Wyoming reviewed the case, focusing on whether the State presented sufficient evidence to support the conviction. The court noted that the standard of review requires assuming the State's evidence is true and giving the State the benefit of every favorable inference. The court found that Landeroz's testimony, despite her memory issues, provided sufficient evidence for the jury to conclude that Robin did not have authorization to use the vehicle at the time of the incident. The court affirmed the conviction, holding that a reasonable jury could have found Robin guilty beyond a reasonable doubt based on the evidence presented. View "Robin v. State" on Justia Law

Logan Gregory Gosselin pled guilty to one count of sexual exploitation of a child and was sentenced to three to eight years in prison, with a recommendation for the Youthful Offender Transition Program (YOTP). Nearing completion of the YOTP, Gosselin filed a motion for sentence reduction, which the district court denied. Gosselin appealed, arguing that the district court abused its discretion and violated his constitutional rights by not honoring an earlier promise to reduce his sentence upon successful completion of the YOTP.The district court of Laramie County initially sentenced Gosselin and included a written judgment suggesting an expectation of sentence reduction if he completed the YOTP. However, the judge who issued the original sentence retired, and a new judge denied Gosselin's motion for sentence reduction without a hearing. Gosselin's appeal contended that the denial was an abuse of discretion and violated his due process and double jeopardy rights.The Wyoming Supreme Court reviewed the case and found that the district court did not abuse its discretion. The court clarified that the written judgment's language about an "expectation" of sentence reduction did not constitute a binding promise. The court also determined that the district court's oral pronouncement did not guarantee a sentence reduction but merely indicated that Gosselin would likely return to court to request it. The Supreme Court held that the district court's denial of the motion did not violate Gosselin's due process rights, as there was no protected interest in a guaranteed sentence reduction. Additionally, the court found no double jeopardy violation, as the denial of the motion did not increase Gosselin's original sentence. The Wyoming Supreme Court affirmed the district court's decision. View "Gosselin v. State" on Justia Law

A detective from the Cheyenne Police Department investigated a break-in and vehicle theft at Swagger Construction on October 10, 2023. The project manager reported missing items, including a company truck and flatbed trailer, and noted "Claim Ins" written on a calendar. The security footage was also missing. The detective later found the stolen trailer on someone's property, loaded with tools, equipment, and a Jeep registered to Andrew Michael Hanson. Hanson was arrested for leaving the scene of an accident while driving the stolen truck. The detective found the missing security footage in the truck, which showed Hanson entering the building through a window and taking items.The State charged Hanson with burglary and felony theft. At trial, the State presented testimony from the arresting officer, the project manager, and the detective, and introduced the security footage as evidence. Hanson moved for a judgment of acquittal, arguing insufficient evidence that he acted without authority. The district court denied the motion, and the jury found Hanson guilty on both counts. He was sentenced to two to four years of incarceration, suspended in favor of three years of probation.The Wyoming Supreme Court reviewed the case, focusing on whether the State presented sufficient evidence for the jury to conclude beyond a reasonable doubt that Hanson acted without authority. The court held that the State provided strong circumstantial evidence, including the project manager's testimony, the security footage, and the detective's findings. The court affirmed Hanson's convictions, concluding that the evidence was sufficient for the jury to reasonably infer that Hanson acted without authority. View "Hanson v. State" on Justia Law

Thomas Hamann brought a lawsuit against Heart Mountain Irrigation District (HMID) and its manager, Randy Watts, alleging that HMID, through Watts' actions, damaged his property and caused him bodily injury. Hamann sought damages based on claims of inverse condemnation and violation of his constitutional rights under 42 U.S.C. § 1983. The district court granted summary judgment in favor of HMID and Watts, dismissing Hamann’s lawsuit entirely. Hamann appealed only the dismissal of his inverse condemnation claim against HMID.The district court found that HMID had not taken any official action to authorize Watts to enter Hamann’s property beyond the limited scope of work on the Riolo bowl, which Hamann had consented to. The court held that without such authorization, Hamann’s inverse condemnation claim could not survive summary judgment. Hamann argued that there was a material issue of fact regarding whether Watts was acting under the scope, authority, and direction of HMID’s board.The Wyoming Supreme Court reviewed the case and found that there were genuine issues of material fact regarding the extent of Watts’ authority and whether his actions were authorized by HMID. The court noted that HMID’s bylaws allowed for delegation of responsibilities to its manager and other agents, and there was evidence suggesting that Watts had general discretion as HMID’s manager. Additionally, there was conflicting testimony about whether Watts had specific authorization to access Hamann’s property beyond the Riolo bowl.The court concluded that the district court erred in granting summary judgment to HMID, as there were unresolved factual issues regarding the authorization of Watts’ actions and the extent of damage to Hamann’s property due to activities on adjoining land. The Wyoming Supreme Court reversed the district court’s order and remanded the case for further proceedings. View "Hamann v. Heart Mountain Irrigation District" on Justia Law

A mother appealed the dismissal of a neglect case brought against her by the State of Wyoming. The case involved her two children, AB and JC. The mother was arrested for drug-related charges, and the children were placed in protective custody. JC was released to his father, who had primary custody, while AB was released to his paternal grandfather and later to his father, who lived in Texas. The State filed a neglect petition, and the juvenile court held hearings, during which the mother denied the allegations. The court initially placed AB with his paternal grandfather and later with his father.The juvenile court found the children had been neglected and ordered continued placement with their fathers while the mother completed a case plan. The State moved to dismiss the neglect petition after the mother made progress on her case plan and AB's father sought custody. The juvenile court initially dismissed the petition but vacated the dismissal after the mother objected. The court later set a permanency review hearing and maintained the status quo, allowing the mother to continue working on her case plan.The State again moved to dismiss the case, noting the mother’s progress and the existence of custody agreements for both children. The juvenile court dismissed the neglect petition, and the mother appealed. The Wyoming Supreme Court found the appeal moot because the State had dismissed the neglect action, and the mother had physical custody of AB. The court concluded that any judgment would have no practical effect on the existing controversy and dismissed the appeal. The court also determined that none of the exceptions to the mootness doctrine applied in this case. View "In the Interest Of: AB and JC" on Justia Law

Timothy Duke was identified as one of the burglars involved in the theft of numerous items from three properties owned by Joseph Walsh in Cheyenne. The stolen items included cash, collectible coins, firearms, trade tokens, and antique police badges. Following an investigation, police recovered some of the stolen items from Duke's home, vehicle, and trailer. Duke was charged with theft over $1,000 and aggravated burglary with a deadly weapon. He pled guilty to the aggravated burglary charge as part of a plea agreement, and the theft charge was dismissed. Duke agreed to pay restitution jointly and severally with his co-defendants.The District Court of Laramie County held a restitution hearing where Walsh testified about the stolen items and their estimated values. The court also considered a presentence investigation report and victim impact statements. The court ordered Duke to pay $507,000 in restitution, finding the State had provided sufficient evidence to support the amount claimed.The Supreme Court of Wyoming reviewed the case to determine if the district court abused its discretion in setting the restitution amount. The court found that Walsh's testimony, the State's supporting exhibits, and the presentence investigation report provided a reasonable basis for the restitution award. Walsh's detailed testimony about the stolen items and their values, corroborated by the presentence investigation report and victim impact statements, was deemed credible and sufficient.The Supreme Court of Wyoming affirmed the district court's restitution order, concluding that the district court did not abuse its discretion and that the restitution amount was supported by sufficient evidence. View "Duke v. State" on Justia Law

Jeremy Clay was arrested for traffic violations and drug offenses on September 23, 2023, and later charged with failure to register as a convicted sex offender. He pled guilty to the failure to register charge and was sentenced to three to five years of incarceration, with all but thirty days suspended, followed by three years of supervised probation. Clay did not appeal the original judgment and sentence. On June 28, 2024, the State filed a petition to revoke his probation, alleging violations including failure to contact his probation agent, leaving Wyoming without permission, and failing to make a required payment. Clay admitted to the violations at a hearing, and the court revoked his probation, sentencing him to nine months in jail, suspended in favor of a split sentence of seventy-two days in jail followed by three years of supervised probation. He timely appealed the probation revocation order.The Wyoming Supreme Court reviewed the case. Clay's appeal focused on alleged violations of his rights during the original criminal proceedings, including claims of Fourth Amendment violations, prosecutorial misconduct, and ineffective assistance of counsel. The State argued that the court lacked jurisdiction to review these claims because Clay did not appeal the original judgment and sentence within the required thirty days.The Wyoming Supreme Court affirmed the district court's order, applying res judicata principles. The court held that Clay's claims were barred by res judicata because he could have raised them in a direct appeal of the original judgment and sentence but failed to do so. The court determined that the parties, subject matter, and issues were the same in both the original criminal proceeding and the probation revocation, and Clay did not show good cause for failing to raise the issues earlier. As a result, Clay was not entitled to relief from the court. View "Clay v. State" on Justia Law

LaToya Adams (Mother) and Dominick Gallegos (Father) are divorced, with Father having primary physical custody of their minor children as per a district court order. Mother filed a motion for an order to show cause, seeking to hold Father in contempt of the custody order, alleging that Father was not allowing her visitation with the children. The district court denied her motion, leading to this appeal.The District Court of Laramie County had previously modified the custody arrangement in August 2023, granting Father physical custody and allowing Mother visitation as deemed safe and appropriate by Father. The order also required the children to remain in counseling and for the parties to follow the recommendations of the counselors regarding visitation. During the hearing, testimony revealed that Father had restricted Mother's contact with the children due to safety concerns, particularly for one child, Y.G., who had significant mental health issues exacerbated by contact with Mother. The district court found that Father acted in good faith based on the therapist's recommendation and did not violate the custody order, thus denying Mother's motion for contempt.The Wyoming Supreme Court reviewed the case and noted several deficiencies in Mother's appeal, including the lack of a designated record and failure to comply with procedural rules. The court found that Mother's brief did not present cogent arguments or pertinent authority to support her claims. Consequently, the Wyoming Supreme Court summarily affirmed the district court's decision, upholding the denial of Mother's motion for an order to show cause. View "Adams v. Gallegos" on Justia Law

Spencer Sharpe (Father) appealed a district court order denying his motion to hold Amy Evans (Mother) in contempt for allegedly withholding his parenting time and excluding him from their children's medical decisions. The parties divorced in 2018, agreeing to share custody, with Mother having final decision-making authority and discretion to withhold Father's parenting time if his mental health was not properly managed. In 2021, both parties sought to modify custody, and the district court found Mother had unreasonably denied Father visitation. The court modified the custody order and held Mother in contempt for past violations.Mother appealed the modification, and the Wyoming Supreme Court upheld the modification but reversed the contempt finding, citing ambiguity in the decree. While the appeal was pending, an incident occurred where Mother took one child from Father's home after an argument, leading to further legal disputes. The district court found Mother in contempt for not allowing supervised visits but did not hold her in contempt for other denials of parenting time due to lack of evidence of Father's compliance with required psychological evaluations.Father filed another motion for contempt, claiming Mother continued to deny his parenting time and interfered with medical decisions. The district court found no willful contempt by Mother and ordered Father to undergo a new psychological evaluation. Father appealed, arguing constitutional violations and ADA issues, but these arguments were not raised in the lower court or pertained to orders not currently under appeal.The Wyoming Supreme Court affirmed the district court's order, finding no error in denying the contempt motion. The court also granted Mother's request for attorney's fees and costs, citing the lack of reasonable cause for the appeal and the absence of cogent argument and relevant legal authority in Father's brief. View "Sharpe v. Evans" on Justia Law

Clifford Bain was seriously injured when a bus owned and operated by the City of Cheyenne collided with him while he was riding his motorcycle. Bain filed a complaint against the bus driver and the City under the Wyoming Governmental Claims Act (WGCA). The bus driver and the City admitted liability but claimed immunity from any liability exceeding $250,000 under the WGCA. Bain then filed a motion for partial summary judgment, arguing that the limitation in § 1-39-118(a)(i) of the WGCA was unconstitutional under Article 10, § 4(a) of the Wyoming Constitution. The district court denied Bain’s motion, declaring the statute constitutional. Bain subsequently filed a petition for writ of review with the Wyoming Supreme Court.The district court denied Bain’s motion for partial summary judgment, holding that § 1-39-118(a)(i) of the WGCA is not a limitation on damages but rather a limitation on the waiver of immunity. Bain then filed a petition for writ of review, which the Wyoming Supreme Court granted.The Wyoming Supreme Court reviewed the case de novo and affirmed the district court’s decision. The Court held that § 1-39-118(a)(i) is a limitation on the waiver of immunity under the WGCA and not a limitation on damages, thus it does not violate Article 10, § 4(a) of the Wyoming Constitution. The Court emphasized that the statute limits the legal responsibility or obligation of governmental entities and is consistent with the legislative intent to balance the equities between injured persons and taxpayers. The Court concluded that Bain did not meet his burden of proving the statute unconstitutional. View "Bain v. City of Cheyenne" on Justia Law