Justia Wyoming Supreme Court Opinion Summaries

A 15-year-old boy shot and killed his former girlfriend, a 17-year-old, after sending her harassing and threatening messages. The confrontation occurred at a park following an exchange with the victim’s cousin, which escalated into a plan to fight. The defendant brought his mother’s handgun to the scene and, during the confrontation, shot the victim in the face as she approached him. He was apprehended shortly after the shooting and confessed to law enforcement.The State originally charged the defendant with first-degree murder and misdemeanor stalking. Pursuant to a plea agreement, he pled guilty to second-degree murder and stalking. At sentencing, the prosecutor and defense agreed that an individualized hearing was appropriate, given the defendant’s juvenile status. The prosecution recommended a sentence of 44 to 75 years for the murder conviction, referencing Wyoming’s Bear Cloud line of cases and statutory limits for juvenile offenders. The defense argued that, under Wyoming law and constitutional principles, the maximum allowable sentence for a juvenile convicted of homicide should be 22.5 years to life, or at most a minimum term not exceeding 43 years. The District Court of Natrona County sentenced the defendant to 42 to 75 years for second-degree murder and time served for stalking.On appeal, the Supreme Court of the State of Wyoming reviewed whether (1) Wyoming’s juvenile parole eligibility statute applied, (2) the sentence exceeded statutory limits, and (3) the sentence violated the Wyoming Constitution’s prohibition on cruel or unusual punishment. The Court held that the parole eligibility statute applied only to life sentences, not to terms of years. The sentence fell within statutory limits for second-degree murder. Finally, the Court found the sentence was not “unusual” under the state constitution because there was no consensus among legislatures or courts that such a sentence for a juvenile was unlawful. The Supreme Court affirmed the district court’s judgment. View "Castaner v. The State of Wyoming" on Justia Law

The case involved allegations that a man sexually abused his stepdaughter, JB, when she was a child and later sexually assaulted his biological daughter, FO, when she was a teenager. After JB disclosed the abuse to her probation officer, both she and FO were interviewed by police and provided accounts implicating the defendant in two separate incidents of sexual intrusion. The State charged the defendant with two counts of first-degree sexual abuse of a minor.During trial proceedings in the District Court of Campbell County, the court granted the defendant’s motion to sequester witnesses. However, it was discovered that JB and FO overheard brief portions of a livestream of the trial while waiting to testify, in violation of the sequestration order. The district court questioned the witnesses outside the jury's presence, found no intentional or prejudicial violation, and allowed limited cross-examination on what they overheard, but did not permit questioning about their violation of a court order. The defendant also moved for mistrials based on allegedly improper testimony referencing uncharged conduct under Wyoming Rule of Evidence 404(b), but the court either struck the testimony and instructed the jury to disregard it or found the testimony did not reference uncharged acts, and denied the motions.On appeal, the Supreme Court of Wyoming reviewed whether the district court abused its discretion in limiting the scope of cross-examination and denying mistrials, and whether the defendant’s Confrontation Clause rights were violated. The court held that the district court acted within its discretion, as the violations of the sequestration order were minimal and non-prejudicial, and the limitations on cross-examination did not infringe on the defendant’s confrontation rights. The court also found no abuse of discretion in denying the motions for mistrial and found no cumulative error. The Supreme Court of Wyoming affirmed the convictions. View "O'Dell v. The State of Wyoming" on Justia Law

The case concerns a shooting incident that occurred late at night in Douglas, Wyoming, when the defendant called 911 to report he had shot his cousin, believing the cousin was breaking into his home. Investigation revealed that the cousin was an invited guest, and the defendant gave inconsistent accounts of the events leading up to the shooting, including claims of memory loss and possible intoxication. Both the defendant and the victim had consumed alcohol and the defendant had used THC. The defendant was charged with first-degree murder and pursued defenses including not guilty by reason of mental illness and self-defense. Psychiatric evaluations offered differing opinions on his mental state, one attributing his actions to a PTSD flashback and the other finding his intoxication contributed to his conduct.In the District Court of Converse County, the defendant moved to dismiss the charges, asserting immunity under a Wyoming self-defense statute. The district court excluded testimony from one of the psychiatric experts, finding it irrelevant under the governing statutes, and further determined that the defendant failed to present competent evidence sufficient to establish a prima facie case for self-defense immunity. The case proceeded to a jury trial, where the defendant was convicted of second-degree murder and sentenced accordingly.Upon appeal, the Supreme Court of the State of Wyoming affirmed the district court’s decisions. It held that the lower court properly excluded the psychiatric testimony as irrelevant to the self-defense immunity issue. The Supreme Court found the defendant failed to present admissible, competent evidence to support a prima facie self-defense claim. It declined to review the jury instruction challenge due to invited error, as the defendant proposed the instruction in question. Finally, the Supreme Court concluded that sufficient evidence supported the conviction for second-degree murder and affirmed the judgment. View "Helms v. The State of Wyoming" on Justia Law

A child born in 2014, RTT, was placed under the co-guardianship of his maternal grandfather, James Serfoss, III, and Mr. Serfoss’s domestic partner, Leslie M. Salmon, beginning in 2016. The two petitioners are not married. In 2025, RTT’s biological father, Tyler Thomas, sought to terminate the guardianship. In response, Serfoss and Salmon jointly counterclaimed, seeking to adopt RTT. The child’s biological mother consented to the adoption, but the biological father did not.Following the joint adoption counterclaim, Mr. Thomas moved to dismiss, arguing that Wyoming law does not permit two unmarried individuals to jointly petition for adoption. The District Court of Converse County certified the legal question to the Supreme Court of Wyoming, asking whether Wyo. Stat. Ann. § 1-22-104(b) allows for a joint adoption petition by two unmarried individuals.The Supreme Court of Wyoming, reviewing the certified question de novo, held that Wyo. Stat. Ann. § 1-22-104(b) does not permit two unmarried individuals to file a joint petition to adopt a minor child. The statute expressly allows joint petitions only for married couples and does not authorize joint petitions by multiple unmarried individuals. The court emphasized that while each unmarried adult may separately petition for adoption, they cannot file jointly; the district court may, however, consolidate separate petitions for consideration. The court declined to read into the statute any broader authority or to interpret legislative silence as permitting joint petitions by unmarried individuals. The Supreme Court’s answer to the certified question was therefore “no.” View "In the Matter of the Guardianship Of: RTT" on Justia Law

The appellant in this case was a member of two limited liability companies, holding approximately a 33% interest. After disputes arose concerning the operation of the LLCs, the appellant initiated litigation seeking dissolution and other relief. Subsequently, he was expelled as a member. The LLCs’ operating agreement required immediate compensation for expelled members’ interests, but the appellant was not paid. While the case was ongoing, the district court enjoined the LLCs from harming the appellant’s interests and appointed a special master to value those interests. Despite the injunction, the appellant’s membership interests were assigned and sold to a third party without his knowledge. The appellant amended his complaint to assert conversion and defamation claims.A jury in the District Court of Park County found for the appellant, awarding $1,784,640 for conversion and $75,000 for defamation per se. Defendants moved post-judgment under Wyoming Rules of Civil Procedure 50(b), 59, and 60, arguing the conversion damages should not exceed the special master’s valuation and that defamation damages lacked evidentiary support. The district court initially denied the Rule 50(b) motion, affirming the jury’s findings. Later, under Rule 60(b), the court reduced conversion damages to $293,017 (the special master’s value) and defamation damages to $500, citing the appellant’s rightful expulsion and lack of proof of reputational harm or economic loss.The Supreme Court of Wyoming reviewed the district court’s reductions. It held that the appellant retained a property interest in the LLCs after expulsion until compensated, and the jury’s conversion award was proper based on fair market value at the time of conversion. For defamation per se, the Court clarified that Wyoming law allows presumed damages above nominal amounts, and sufficient evidence supported the jury’s $75,000 award. The Supreme Court reversed the district court’s reductions and reinstated the original jury awards. View "Mccall v. Best of the West Productions, LLC" on Justia Law

Police officers in Casper, Wyoming stopped a woman driving with her infant child and an adult passenger, believing the vehicle’s cracked windshield violated traffic laws and suspecting the passenger had active warrants. After arresting the passenger and searching the vehicle with the driver’s consent, officers discovered suspected methamphetamine in the driver’s backpack. The driver admitted to recent drug use and consented to a search of her apartment, where more methamphetamine was found. She was charged with felony child endangerment and misdemeanor possession, accused of allowing her child to remain in places where she knew methamphetamine was present.The driver filed a motion in the District Court of Natrona County to suppress evidence from the vehicle and apartment searches, arguing the traffic stop was unjustified and her consent and statements were involuntary. The district court denied the motion, finding the stop was lawful, Miranda warnings were not required, and her statements were voluntary. She then entered a conditional guilty plea to child endangerment, reserving the right to appeal the suppression ruling, and was sentenced to probation under a plea agreement. The misdemeanor possession charge was dismissed.On appeal, the Supreme Court of Wyoming reviewed the validity of the conditional guilty plea under Wyoming Rule of Criminal Procedure 11(a)(2). The Court found that while the plea satisfied the requirements for written reservation, State consent, and district court approval, it failed because not all issues reserved for appeal were dispositive. Only the challenge to the legality of the initial stop would end the case if resolved in appellant’s favor, while the other issues would not. The Supreme Court of Wyoming held the conditional plea was invalid and vacated the judgment and sentence, remanding for further proceedings. View "Stone v. State of Wyoming" on Justia Law

Dixon Dean Cole was originally charged in 1996 with multiple counts of sexual assault and immoral or indecent acts with minors. Through a plea agreement, he pled guilty to one count of sexual assault in the fourth degree (a misdemeanor) and one count of immoral or indecent acts with a minor (a felony). He received suspended sentences and probation, and after fulfilling all court-ordered requirements, he was discharged from probation in 2001. Both convictions required him to register as a sex offender due to the ages of the victims.Years later, Cole was charged with failing to register as a sex offender. While those charges were pending, he sought expungement of both convictions and requested to be relieved of his registration duty. The District Court of Sweetwater County expunged his misdemeanor conviction (applying the felony expungement statute in error) and terminated his duty to register for the felony conviction. The State objected, arguing Cole was statutorily ineligible for expungement due to his registration status.On appeal, the Supreme Court of Wyoming determined that although the district court used the incorrect statute for the misdemeanor expungement, Cole was otherwise eligible under the proper statute, and the results would have been the same. The Court declined to consider arguments about whether Cole posed a danger to society, as these were not properly raised in the district court. Regarding the termination of the sex offender registration requirement, the Supreme Court found no abuse of discretion, noting Cole met all statutory prerequisites and that a pending failure-to-register charge did not automatically bar relief.The Supreme Court of Wyoming affirmed both the expungement of the misdemeanor conviction and the order terminating Cole’s duty to register as a sex offender. View "State v. Cole" on Justia Law

Lloyd Haack passed away in March 2024, leaving behind a purported will that named his son, Howard Haack, as the sole beneficiary and personal representative. Shawn Renee Logan, claiming to be Mr. Haack’s financial advisor, petitioned for probate and expressed belief in another will, but no such document was found. The court admitted the existing will to probate and appointed Howard Haack and Bailey Baxter as co-personal representatives. Logan contested Howard’s appointment, alleging forgery, but her petition was dismissed for lack of standing. Kristy Martinez, Haack’s granddaughter, was determined to have standing to contest both the will and the appointment. She then filed a petition contesting the will’s validity within the probate case, requested a jury trial, and the co-personal representatives responded with affirmative defenses and a motion to dismiss, arguing the will contest required a new civil action separate from the probate matter.The District Court of Fremont County held a hearing to address these procedural questions. The co-personal representatives relied on prior Wyoming Supreme Court decisions, including Matter of Estate of Meeker and Matter of Estate of Rowe, arguing that statutory requirements and civil procedure rules necessitated a separate civil action for will contests. Martinez, however, argued that Wyoming law permits such contests to proceed within the probate matter itself and cited Gaunt v. Kansas University Endowment Association and Russell v. Sullivan for support.The Supreme Court of Wyoming reviewed the certified questions from the district court. Employing statutory interpretation and examining relevant precedent, the Court held that Wyoming statutes do not require a will contest to be filed as a completely separate civil action with a new case number and heading. Instead, a will contest under Wyo. Stat. § 2-6-301 et seq. can proceed as a separate proceeding within the existing probate matter. Accordingly, the Court answered the certified question in the negative and declined to address the second question regarding jurisdictional defects. View "In the Matter of the Estate of Haack" on Justia Law

The case concerns an altercation in Sheridan, Wyoming, during which Cody McCalla and his friend encountered Patrick Mudd and Mudd's girlfriend over a parking dispute. After a verbal confrontation, McCalla and his friend moved their vehicle and proceeded toward the fairgrounds. Mudd stood on the sidewalk, and a second confrontation ensued between McCalla and Mudd, escalating into physical violence. After several exchanges, McCalla ultimately punched Mudd, causing him to fall, hit his head, and later die from his injuries. McCalla was charged with involuntary manslaughter.The District Court of Sheridan County reviewed several pretrial motions. McCalla moved to compel production of unredacted law enforcement reports, which the district court denied, finding the redacted portions exempt from disclosure under Wyoming Rule of Criminal Procedure 16. McCalla also moved to dismiss the charge, claiming immunity from prosecution under Wyoming Statute § 6-2-602(f) on grounds of self-defense. The district court held an evidentiary hearing, requiring McCalla to proceed first, as his motion alone did not establish a prima facie case. After testimony, the district court found McCalla met his prima facie burden, but the State proved by a preponderance of evidence that McCalla was the initial aggressor in the second altercation and did not use reasonable defensive force, denying immunity.The Supreme Court of Wyoming reviewed the appeal. It held the district court did not err in requiring McCalla to proceed first at the evidentiary hearing, found no error in the district court’s determination that McCalla was the initial aggressor and thus not entitled to self-defense immunity under Wyoming Statute § 6-2-602(f), and declined to address the discovery issue, as it was not properly preserved for appeal. The Supreme Court affirmed the district court’s rulings. View "Mccalla v. The State of Wyoming" on Justia Law

A Wyoming firearms manufacturer sought to expand its operations by constructing a new facility. The company, unable to directly access specific state economic development funds, partnered with a city and a local non-profit to obtain funding, resulting in a written agreement outlining each party’s roles. The non-profit was charged with managing the project, including hiring architects and contractors. During and after construction, the manufacturer identified substantial design and construction defects, including climate control problems, leaks, and structural issues. The manufacturer sued the non-profit for breach of contract and also sued the architect and contractor, asserting it was a third-party beneficiary of their contracts with the non-profit.In the District Court of Park County, the court dismissed the manufacturer’s claims against the architect and contractor, finding it was not an intended third-party beneficiary under their contracts, and granted summary judgment to the non-profit on all but one claim, determining that the non-profit’s contractual obligations were limited to financial administration of the project. The remaining claim was later dismissed by stipulation.The Supreme Court of Wyoming reviewed the case de novo. The court held that the district court erred in dismissing the manufacturer’s claims against the architect and contractor because, accepting the complaint’s factual allegations as true and considering the relevant contracts, the manufacturer had sufficiently alleged facts that could support third-party beneficiary status and breach of contract. The court also found the district court erred in granting summary judgment to the non-profit, concluding that the contract’s language and context imposed broader duties on the non-profit, including project administration and construction oversight, not merely financial management. The Supreme Court of Wyoming reversed the lower court’s orders of dismissal and summary judgment, allowing the manufacturer’s claims to proceed. View "Gunwerks, LLC v. Forward Cody Wyoming, Inc." on Justia Law