Justia Wyoming Supreme Court Opinion Summaries

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

The parties in this case were married from 1998 until their divorce in 2025. During the marriage, the wife acquired thirty shares in her employer’s business, Plan One Architects, after the couple jointly decided to invest. The shares were purchased using loans from the husband’s mother, refinancing their home, and selling a car. Plan One’s bylaws require only employees to hold shares, so the wife solely owns them and must sell them back to the company when her employment ends. The value of the shares primarily comes from annual shareholder distributions, which comprise most of the wife’s income.The District Court of Park County held a bench trial to resolve disputes over the division of the Plan One shares and associated debts. It found the shares to be marital property acquired during the marriage, largely due to the wife’s loyalty to her employer and financial support from the husband’s mother. The court ordered the wife to pay the husband one-half of the annual distributions from the shares, minus associated taxes, until her employment ends. Additionally, the court required both parties to equally repay the outstanding loans to the husband’s mother. Upon the wife's eventual sale of the shares, she must pay the husband one-half of the sale proceeds, minus capital gains taxes.On appeal, the Supreme Court of Wyoming reviewed whether the district court erred in awarding the husband half of the distributions, assigning tax liability to the wife, and directing repayment of the debt to the husband’s mother. The Supreme Court held that the shares were a vested marital asset and affirmed the district court’s discretion in awarding the husband periodic property distribution payments, assigning tax responsibility to the wife, and dividing the marital debt. The district court’s decree was affirmed. View "Atkinson v. Atkinson" on Justia Law

Law enforcement responded to a welfare check at a hotel where a mother and her two young children were staying. Upon investigation, officers discovered evidence of methamphetamine use and poor living conditions, including malnutrition and neglect of the children. The children were taken into protective custody, and the mother was arrested and charged with endangering children. During the dependency proceedings, the mother gave birth to a third child, who was also removed after testing positive for methamphetamine at birth. Over the next two years, the mother struggled with housing instability, inconsistent visitation with her children, repeated incarceration, and ongoing substance abuse.The State of Wyoming, through the Department of Family Services (DFS), filed neglect and later termination petitions in the District Court of Fremont County. The mother participated in case planning and received services but failed to meet critical goals, such as obtaining safe housing, maintaining sobriety, and engaging consistently with her children. The district court conducted a bench trial and, after considering evidence of the mother’s continued substance abuse, incarceration, and inability to care for the children, terminated her parental rights under Wyoming Statute §§ 14-2-309(a)(iii) and (a)(v). The court found that DFS made reasonable efforts to reunify the family and that termination was in the children’s best interests.The Supreme Court of the State of Wyoming reviewed the case, applying a strict scrutiny standard and examining whether the evidence supported termination under either statutory ground. The court held that DFS’s procedural shortcomings did not prevent the mother from understanding or completing her case plan and distinguished this situation from MB v. Laramie County Department of Family Services, 933 P.2d 1126 (Wyo. 1997). Because the mother failed to challenge termination under § 14-2-309(a)(v), the court affirmed the district court’s decision to terminate her parental rights on that independent ground. View "In re Termination of Parental Rights To: BAC II" on Justia Law

A sixteen-year-old girl, after suffering a rape, was admitted to an adolescent psychiatric unit for mental health treatment. While in the facility, she alleged that another patient, Z.L., touched her buttocks with his foot and later, while she was awake, put his hand down her pants and touched her vagina. The incident allegedly occurred in a common room under indirect staff supervision. After reporting the event and undergoing a sexual assault exam, she was discharged from the facility three days later. Her co-conservators filed a medical malpractice action against the health facility, claiming that inadequate supervision enabled the alleged assault and caused her further harm.The matter proceeded to a seven-day jury trial in the District Court of Campbell County. The court approved a special verdict form with a threshold question asking whether Z.L. “inappropriately touched” the plaintiff; the form did not define this term. The jury answered the question in the negative and returned a verdict for the defendant hospital. The plaintiffs objected to the structure of the verdict form and the absence of a legal definition for “inappropriate touch.” They moved for a new trial, which was denied, and the court awarded costs to the defendant after finding the plaintiffs’ objections to costs untimely.The Supreme Court of Wyoming reviewed the case. It held that the plaintiffs had properly preserved their objections for appeal, but found no error in the special verdict form or jury instructions, concluding that the language used was consistent with the evidence and arguments presented. The court determined the district court did not abuse its discretion in responding to jury questions, denying a new trial, or awarding costs. The Supreme Court affirmed the judgment, denial of a new trial, and the award of costs. View "Rose v. Campbell County Health" on Justia Law

A child, BEP, was born in November 2022 and soon after was hospitalized due to breathing difficulties and low weight, leading to concerns about his mother’s ability to care for him. The mother had inappropriately watered down formula and given BEP medicine unsuitable for his age. As a result, BEP was placed in protective custody and later foster care under the Wyoming Department of Family Services (Department), while paternity was being established. The Department identified Skylar Colten Remer as BEP’s legal father in May 2023 and developed a case plan to help him establish a safe relationship with BEP, which included counseling, supervised visitation, and parenting coaching. Despite these efforts, the Department found Father did not engage in the services provided, failed to demonstrate meaningful change, and was unable to provide basic or higher-level care for BEP, who had significant behavioral and emotional needs.The Department petitioned the District Court of Natrona County to terminate Father’s parental rights under Wyo. Stat. Ann. § 14-2-309(a)(iii) and (v), citing Father’s neglect, instability, and lack of engagement. Father failed to timely respond to the petition, resulting in a default being entered against him. At the subsequent termination hearing, Father could cross-examine witnesses but could not present his own evidence. The district court found clear and convincing evidence supporting termination on both statutory grounds and concluded termination was in BEP’s best interest.On appeal, the Supreme Court of Wyoming reviewed whether sufficient evidence supported the district court’s decision. The Court held that clear and convincing evidence established that BEP had been in foster care for the required period and that Father was unfit to have custody and control of BEP, as required by Wyo. Stat. Ann. § 14-2-309(a)(v). The Supreme Court of Wyoming affirmed the district court’s termination of Father’s parental rights. View "In the Matter of the Termination of Parental Rights To: BEP" on Justia Law

A landowner sought to establish a private road across a neighboring ranch property to access an isolated parcel it owns, which is largely surrounded by the neighbor’s land. The landowner made unsuccessful attempts to negotiate an easement, then filed a petition under Wyoming’s private road statute to secure access. The parcel in question lacks legally enforceable vehicle access except through the neighbor’s land. Various options for routes, including one passing through public land, were considered, but physical and legal barriers precluded public access.The District Court of Albany County held a bench trial, appointed viewers and appraisers to review potential routes, and ultimately established a private road along the landowner’s proposed route, finding it to be the most reasonable and convenient. The court awarded damages to the neighbor based on a “before and after” appraisal, and imposed several conditions on the private road. The landowner appealed three of those conditions, while the neighbor cross-appealed, challenging the findings of good faith, necessity, route selection, damages, and denial of an agricultural-use-only restriction.The Supreme Court of Wyoming affirmed the district court’s findings of good faith, necessity, route selection, and damages, as well as its rejection of the agricultural-use-only restriction. The court concluded that the parcel was landlocked and that neither the purported public land route nor alternative bypasses provided legally enforceable access. It found the chosen route was most reasonable and convenient and that damages were properly calculated. However, the Supreme Court reversed two conditions imposed by the district court—specifically, the requirement that the landowner repair any damage regardless of fault, and the restriction on vehicles with more than four axles—because they were not supported by evidence. The remaining challenged condition and the denial of the agricultural-use-only restriction were affirmed. View "Wagonhound Land & Livestock Company, LLC v. Little Medicine Creek Ranch, Inc." on Justia Law

The appellant owns a one-story home in Laramie County, Wyoming. In April 2024, the Laramie County Assessor valued her property at $188,822. After the appellant objected, field appraisers inspected the home, which led to a series of adjustments, ultimately lowering the valuation to $164,939. Throughout these valuations, the home’s condition was rated as “average” and its quality as “low.” The appellant contended that her home’s value should be reduced further, citing its age, lack of updates, limited livable space, and certain deficiencies such as a non-livable basement and outdated construction features.Following an appeal by the appellant, the Laramie County Board of Equalization held a contested hearing. The appellant presented evidence including her home’s purchase price, its physical shortcomings, and comparisons to other neighborhood homes. The Board heard testimony from the Assessor regarding the process for property valuation and the guidelines for assigning condition ratings. Despite the field appraisers’ assessment, the County Board, by a 3-2 vote, determined that the condition should be downgraded from “average” to “fair” and remanded the matter to the Assessor for reclassification. The Board based its decision on limited photographic evidence and the appellant’s testimony.The Assessor appealed to the Wyoming State Board of Equalization, which reversed the County Board’s decision, finding it was not supported by substantial evidence. The district court affirmed the State Board. On further appeal, the Supreme Court of Wyoming reviewed only the County Board’s decision. The Supreme Court held that the County Board’s determination to downgrade the property’s condition was not supported by substantial evidence, as the appellant did not present credible evidence sufficient to rebut the presumption in favor of the Assessor’s valuation. The Supreme Court reversed the County Board’s decision. View "Gummel v. Laramie County Assessor" on Justia Law