Justia Wyoming Supreme Court Opinion Summaries

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

Wyoming’s Constitution requires the legislature to provide a thorough and efficient education for all students. Historically, public education was funded by local property taxes, resulting in significant disparities between districts. Decades of litigation and legislative reform led to a statewide, cost-based funding model for school operations and facilities. This model, known as the legislative model (LM), was intended to ensure equal educational opportunities by using a block grant system based on the estimated cost of an adequate education (the “basket of goods and services”). Periodic recalibrations and annual adjustments for inflation were required to keep the model current.The plaintiffs, including the Wyoming Education Association and several school districts, sued in 2022, alleging that the legislature’s funding model was no longer cost-based, wasn’t properly adjusted for inflation, and lacked funding for certain innovations such as elementary school counselors, nutrition services, and school resource officers. They also claimed the State’s facilities oversight was inadequate. The District Court of Laramie County, after a bench trial, found in favor of the plaintiffs on all issues, concluding that the legislature failed to fund actual costs, address inflation, and include necessary innovations, and that the State’s facilities process was constitutionally deficient.The Supreme Court of Wyoming reviewed the case. The Court affirmed the district court’s findings that the legislature violated students’ equal protection rights by failing to fund the true cost of teacher salaries and by not properly adjusting for inflation. However, it reversed the requirement to fund a one-to-one technology ratio, nutrition services, and school resource officers, finding insufficient evidence that these innovations required statewide funding. The Court also reversed the order requiring statewide assessment of educational suitability for facilities, holding the State’s administrative process was constitutionally adequate. The Court ended the lower court’s retention of jurisdiction, assuming the legislature would act in good faith to comply with constitutional requirements. View "The State of Wyoming v. Wyoming Education Association" on Justia Law

The appellant was charged with conspiracy to deliver fentanyl in Natrona County, Wyoming. Before he could be arrested in Wyoming, he traveled to Iowa, where he was apprehended after committing additional criminal offenses involving fleeing from police. He was incarcerated in Iowa for 259 days pending resolution of those Iowa charges. After pleading guilty and receiving probation in Iowa, he became available for extradition to Wyoming, where he was ultimately convicted and sentenced to prison. He requested credit toward his Wyoming sentence for the entire period of Iowa incarceration, arguing that his Iowa confinement was caused by the Wyoming charges.In the District Court of Natrona County, the judge awarded the appellant 307 days of credit, starting from the date the Iowa charges were resolved and he became available for extradition to Wyoming, until his Wyoming sentencing. The court denied credit for the 259 days he spent in Iowa prior to resolution of the Iowa case, finding that this period of confinement was attributable to his Iowa offenses, not solely to the Wyoming charge. The appellant filed a motion to correct his sentence and also sought appointment of counsel for his appeal. The district court denied both motions.Upon review, the Supreme Court of Wyoming held that the appellant is not entitled to credit for the 259 days of Iowa confinement because his incarceration during that time was due to independent Iowa criminal charges and would have persisted regardless of his ability to post bond in Wyoming. The court also determined that the district court’s judgment and sentence complied with Rule 32 requirements. Additionally, the Supreme Court of Wyoming concluded it lacks jurisdiction to consider the denial of appointed counsel because the appellant did not properly appeal that order. The district court’s denial of the motion to correct an illegal sentence was affirmed. View "Melber v. The State of Wyoming" on Justia Law

After being arrested during a traffic stop in April 2024, the defendant faced multiple criminal charges in Laramie County, Wyoming. At the time, he was already on probation for prior misdemeanor offenses and had an outstanding warrant in a separate felony case. Following the arrest, he was charged with new felonies and misdemeanors, and his probation was eventually revoked, resulting in the imposition of the underlying misdemeanor sentence. Over the subsequent months, he remained in custody at various points for reasons including probation violations and failure to appear, and he ultimately entered guilty pleas to select charges in two felony cases pursuant to a plea agreement.The District Court of Laramie County, after accepting the plea agreement, sentenced the defendant to concurrent terms of imprisonment on the felony charges. At sentencing, the parties disputed the amount of credit for presentence confinement to be applied to his sentences. The State argued that he was entitled only to credit for days spent in custody after completion of his misdemeanor sentence, while the defendant sought credit for nearly all days spent in custody between his arrest and sentencing. The district court initially awarded 56 days of credit, later increasing this to 64 days after further argument, but declined to grant additional credit for periods during which the defendant was serving his misdemeanor sentence.The Supreme Court of Wyoming reviewed the legality of the sentence, specifically the award of credit for presentence confinement. The court held that, under Wyoming precedent, a defendant is only entitled to credit against concurrent sentences in separate cases for time spent in custody if that confinement was due solely to a financial inability to post bond. Because the defendant was in custody for probation revocation and serving a sentence in another case, rather than solely due to an inability to post bond, he was not entitled to additional credit. The Supreme Court of Wyoming affirmed the district court’s judgment. View "Gauna v. State" on Justia Law

Law enforcement agents in Rawlins, Wyoming, surveilled suspects believed to be involved in drug distribution. During this operation, officers observed two known drug users at the residence of an individual who was not originally a target. After one of these individuals left, she was stopped for a traffic violation, and a drug detection dog conducted a search but found no contraband. Subsequently, officers followed the resident, observed him commit a traffic violation, and conducted a traffic stop. During the stop, a drug detection dog alerted to the presence of drugs in the vehicle, leading to a search that recovered significant quantities of methamphetamine, marijuana, and a firearm. Additional evidence was found at the individual's home and on his person. He was charged with multiple drug and firearm offenses and misdemeanors.The District Court of Carbon County conducted pretrial hearings on the admissibility of evidence, including evidence under Wyoming Rule of Evidence 404(b) and the validity of the traffic stop. The district court admitted text and Facebook messages between the defendant and various individuals, which referenced drug activity using coded language, concluding they were relevant to the charges and their probative value was not substantially outweighed by unfair prejudice. The court denied the defendant’s motion to suppress the evidence from the traffic stop, finding reasonable suspicion existed, and later denied a request to file a late motion to suppress related to the drug dog’s alert. At trial, the jury convicted the defendant on most charges, and the district court imposed sentences accordingly.On appeal, the Supreme Court of Wyoming considered whether the defendant had waived his right to challenge the dog sniff and whether the district court erred in admitting the 404(b) evidence. The court held that the defendant waived his challenge to the dog sniff by failing to raise it in a timely manner and did not demonstrate good cause for this failure. Additionally, the court found no abuse of discretion in admitting the messages, concluding the district court properly applied the required evidentiary framework. The Supreme Court of Wyoming affirmed the convictions. View "Brown v. The State of Wyoming" on Justia Law

Cowboy Racing was formed in Wyoming with two members: EFTI, which held a 51% interest and was managed by William Edwards, and Dillinger’s, with a 49% interest, managed by Ryan Clement. The company’s operating agreement appointed Edwards and Clement as the initial managers and set out procedures for removing a manager, including both a for-cause provision and a mechanism for removal with the consent of a majority interest. In February 2025, EFTI, holding the majority interest, removed Clement as a manager citing his unauthorized expenditures. Despite his removal, Clement continued to act as though he had authority on behalf of Cowboy Racing.EFTI and Cowboy Racing then filed suit in the District Court of Laramie County, seeking a declaration that Clement could not act on behalf of the company, enforcement of a purchase right under the operating agreement, damages for breach of a letter of intent, and, relevant here, a preliminary injunction to prevent Clement from representing himself as a manager. Clement objected, arguing that the removal process was procedurally and substantively improper and conflicted with the operating agreement.The Supreme Court of the State of Wyoming reviewed the district court’s grant of the preliminary injunction, applying an abuse of discretion standard. The Court held that while the district court’s order was inartfully phrased as a final determination, it properly found that Cowboy Racing and EFTI were likely to succeed on their claim that Clement was lawfully removed under the operating agreement. The Court concluded the agreement was unambiguous and that EFTI, as the majority member, had the authority to remove Clement with express written consent. The preliminary injunction was affirmed, but the parties retain the right to present further evidence at trial on the merits. View "Dillinger's LLC v. CR-GTD, LLC" on Justia Law

A man and his wife experienced a tumultuous marriage marked by frequent conflict and the issuance of mutual protection orders. The couple eventually separated, and the wife, along with their children, moved out. During and after their separation, the husband violated a modified protection order that restricted his contact with his wife to matters relating to their children and prohibited any abuse or conduct likely to cause her fear. The state filed two sets of criminal charges against the husband, including witness intimidation, stalking, and multiple counts of violating a protection order. The cases were joined for trial. Evidence presented at trial included numerous communications from the husband to his wife, some of which the wife described as threatening or emotionally distressing.The District Court of Uinta County presided over the trial. The court excluded certain evidence regarding the wife’s past conduct, deeming it irrelevant or more prejudicial than probative, and limited the admissibility of other evidence on similar grounds. A jury acquitted the husband on two counts of violating a protection order but convicted him on all remaining charges. The district court orally sentenced the husband to specific jail terms but entered written sentencing orders that were inconsistent with the oral pronouncement, including indeterminate sentences for misdemeanors and conflicting statements about the order in which sentences would be served.The Supreme Court of Wyoming reviewed the case. It held that the district court did not abuse its discretion by excluding most evidence of the wife’s conduct, finding such evidence irrelevant to the husband’s specific intent or the elements of the crimes charged, and that the exclusion did not violate his constitutional rights. The court also held that the evidence was sufficient to support the witness intimidation conviction, as the husband's statements constituted threats under the statute. However, it found that the written sentencing orders imposing indeterminate misdemeanor sentences were illegal and that the chronological order of sentences was unclear. The court affirmed the convictions but reversed and remanded for correction and clarification of the written sentencing orders. View "Walker v. The State of Wyoming" on Justia Law

A young child, TF, was using the men’s restroom at a Walmart when James Neil Todd entered. Shortly after, TF told his mother that Mr. Todd had asked him if he wanted to touch Mr. Todd’s “wiener” while Mr. Todd’s penis was exposed. The mother reported the incident to store staff and police. Mr. Todd was quickly located by law enforcement, and he admitted his penis was exposed in the restroom but denied asking the child to touch it, instead claiming the child may have misunderstood the situation due to an urgent need to urinate. The State charged Mr. Todd with attempted sexual exploitation of a child, alleging he knowingly attempted to entice TF to engage in explicit sexual conduct by exposing his penis and asking TF if he wanted to touch it.The District Court of Campbell County held a jury trial, where the jury found Mr. Todd guilty. Mr. Todd was sentenced to a prison term, suspended in favor of jail time and supervised probation. On appeal to the Supreme Court of Wyoming, Mr. Todd argued there was insufficient evidence to support his conviction and that the district court erred in refusing to give a jury instruction defining “lascivious.”The Supreme Court of Wyoming affirmed the conviction. The Court held the evidence was sufficient for a reasonable jury to conclude Mr. Todd took a substantial step toward causing, inducing, or enticing a child to engage in explicit sexual conduct, specifically masturbation, as defined by statute. The Court also held that the district court did not abuse its discretion by declining to give Mr. Todd’s proposed jury instruction defining “lascivious,” as the State was not required to prove a lascivious exhibition to sustain the conviction and the term should be given its ordinary meaning. The judgment of the district court was affirmed. View "Todd v. The State of Wyoming" on Justia Law

A man and a woman began a relationship in 2015 and had a child in 2018. Though they were never married, they lived together until 2024. After their separation, they informally shared custody of their child, alternating time with her. In 2025, the mother unilaterally moved to Colorado with the child, initially telling the father it was a temporary visit but intending to relocate permanently. The father responded by filing for custody, visitation, and child support, and sought emergency temporary custody due to the mother’s relocation. Both parents accused each other of substance abuse but drug tests were negative.The District Court of Park County held hearings and initially awarded temporary physical custody to the mother and joint legal custody to both parents, with regular drug testing and structured visitation for the father. At a subsequent bench trial, the court continued physical custody with the mother pending a final order. Ultimately, in its final order, the court found both parents fit and competent, but awarded the mother primary physical custody, citing the child’s enrollment in school in Colorado and the stability of the mother’s home as serving the child’s best interests. The father was granted substantial visitation, including four consecutive nights each month, alternating holidays, and eight weeks each summer. The court declined to award child support to either party because of the father’s travel costs.On appeal, the Supreme Court of the State of Wyoming reviewed the district court’s custody order for abuse of discretion. The Supreme Court affirmed the district court’s decision, holding that the district court did not abuse its discretion in awarding the mother primary physical custody. The Supreme Court found the district court’s findings were supported by the record and that its decision reasonably balanced the child’s best interests and the practical challenges posed by the parents’ geographic separation. View "Swindler v. Bright" on Justia Law