Justia Wyoming Supreme Court Opinion Summaries

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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence, holding that Defendant's claim was barred by res judicata.Defendant pled guilty to two counts of forgery, two counts of burglary, and one count of aggravated burglary. Defendant challenged his sentences on multiple occasions. At issue on appeal were Defendant's two motions to correct an illegal sentence, filed in 2018 and 2020. The district court denied both motions. On appeal from the denial of his latest motion, Defendant argued that he was entitled to credit against his Wyoming sentences for time spent in Colorado. The Supreme Court affirmed, holding that because Defendant already litigated his claim, he was now barred from raising that claim. View "Russell v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the district court granting summary judgment for Plaintiff on his claim to quiet title in his window wells that encroached on Defendant's property based on adverse possession, holding that the district court did not err.Plaintiff filed a complaint requesting declaratory judgment that he was the owner of the disputed window wells by virtue of adverse possession, a decree quieting title in his name, and a preliminary injunction preventing Defendant from removing the window wells or otherwise damaging his home. The district court granted summary judgment for Plaintiff, finding that Plaintiff met his burden of making a prima facie showing of adverse possession. The Supreme Court affirmed, holding (1) Plaintiff made a prima facie claim for adverse possession of the window wells, and Defendant failed to show a disputed issue of material fact; and (2) the district court did not commit procedural errors that prejudiced Defendant and properly granted summary judgment in favor of Plaintiff. View "Woodward v. Valvoda" on Justia Law

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The Supreme Court affirmed the judgment of the district court in favor of Saratoga Inn Overlook Homeowners Association, Inc. (HOA2) on its claim for breach of fiduciary duty and awarding punitive damages, holding that the district court did not abuse its discretion.In developing the Saratoga Inn Overlook Subdivision, Orion Point LLC, whose sole members were Cynthia Bloomquist and Chris Shannon, established the Saratoga Inn Overlook Homeowners Association, Inc. (HOA1). When HOA1 was dissolved, Bloomquist unilaterally formed HOA2. Bloomquist then sold Orion Point's lots in the subdivision and conveyed the common area to Prancing Antelope I, LLC. HOA2 brought this action against Bloomquist, Shannon, and Prancing Antelope, asserting several claims. The district court granted summary judgment for HOA2 on its claim for ejectment. The Supreme Court affirmed, holding (1) HOA2 was entitled to summary judgment on its ejectment claim; (2) Wyo. R. Civ. P. 19 did not require the joinder of members of HOA1; and (3) the district court did not abuse its discretion when it awarded attorneys' fees as punitive damages. View "Prancing Antelope I, LLC v. Saratoga Inn Overlook Homeowners Association, Inc." on Justia Law

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The Supreme Court affirmed Defendant's conviction for first-degree sexual assault, holding that the State's delay in bringing charges against him did not violate due process and that the prosecutor's comments during closing argument did not constitute plain error.On appeal, Defendant argued, among other things, that the prosecutor improperly commented on his right to remain silent during closing argument. The Supreme Court disagreed, holding (1) Defendant failed to show that the State's delay in charging him violated his right to due process; and (2) Defendant failed to show that the prosecutor's statements during closing argument violated a clear and unequivocal rule of law in a clear and obvious way. View "Ridinger v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's conviction of third-degree sexual abuse of a minor, TM, holding that the district court did not commit plain error by admitting evidence of TM's out-of-court statements about the abuse.On appeal, Defendant argued that the district court erred by admitting into evidence TM's prior consistent out-of-court statements and by allowing the jury to review, during deliberations, a clip of a muted video of Defendant and a police officer walking through the bedroom where the abuse occurred. The Supreme Court affirmed, holding (1) the district court's admission of TM's out-of-court statements about the abuse was proper; and (2) Defendant failed to demonstrate that there was a reasonable probability the verdict would have been more favorable to him if the district court had refused the jury's request to view the contested video. View "Hicks v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the district court revoking Defendant's probation, holding that the State presented sufficient evidence to prove that Defendant violated the terms of his probation, and the district court did not abuse its discretion by ordering the revocation.Defendant pleaded guilty to several burglaries and was sentenced to a term of imprisonment, suspended in favor of probation. The State later moved to revoke Defendant's probation not he grounds that he violated the terms by committing the crime of attempted burglary. The district court revoked Defendant's probation. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it determined that the State had proved that Defendant violated his probation by a preponderance of the evidence. View "Stroble v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the district court dismissing Petitioners' verified petition for adoption requesting that the court enter an order of adoption recognizing MB's medically established age and directing the issuance of a Wyoming birth certificate with an accurate date of birth, holding that the district court erred.Petitioners adopted a minor, MB, from the Henan Province, Zhengzhou, People's Republic of China. The United States Department of State issued a Hague Adoption Certificate certifying the adoption. Later, MB's pediatrician determined that MB's documented age was incorrect and that MB was actually two years younger than the age listed on the official paperwork. Petitioners then filed the petition at issue. The district court dismissed the petition, concluding that it lacked subject matter jurisdiction and that approval of the adoption was moot because the Hague Convention adoption must be recognized as valid and final. The Supreme Court reversed, holding that the district court (1) had subject matter jurisdiction to approve The Hague Convention adoption; and (2) was statutorily authorized to issue a decree of adoption allowing MB to obtain a Wyoming birth certificate with an accurate date of birth. View "In re Adoption of MAJB" on Justia Law

Posted in: Family Law
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In this property dispute, the Supreme Court reversed the judgment of the district court finding largely in favor of Larry Wagoner, holding that the oral contract between the parties in this case was void.Donald Fuger and Wagoner entered into an oral agreement to construct two buildings on a portion of the Fugers' property. When the buildings were completed Wagoner occupied one and rented the other for several years. Fuger and wife later sued Wagoner and his wife seeking to evict them from the property. Wagoner, in turn, sued the Fugers, alleging contract and equitable theories for ownership of one building and the underlying property. The district court held that an enforceable oral contract existed between Fuger and Wagoner and awarded Wagoner $302,234 plus post-judgment interest. The court did not reach Wagoner's equitable claims. The Supreme Court reversed, holding that the district court erred in finding that a valid oral contract between Wagoner and Fuger existed. The Court remanded for consideration of Wagoner's equitable claims. View "Fuger v. Wagoner" on Justia Law

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The Supreme Court affirmed Defendant's conviction of second degree sexual abuse of a minor, holding that the district court did not err in denying Defendant's motion for judgment of acquittal, the evidence was sufficient to support the conviction, and the prosecutor made two improper statements in rebuttal argument, but the statements did not prejudice Defendant when considered together.Specifically, the Supreme Court held (1) the State produced sufficient evidence of "touching under the statutory definition of sexual contact and evidence that Defendant touched the victim with the "intent of sexual arousal, gratification, or abuse"; and (2) the prosecutor made two improper statements during rebuttal argument, but, cumulatively, the improper statements did not deprive Defendant of a fair trial. View "Armajo v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the district court granting Defendant's motion to compel arbitration under the "voluntary agreement for arbitration" Rick Miller signed on behalf of his mother, Julia Miller, after she was admitted to Life Care Center of Casper (LCCC), holding that Rick lacked authority to execute the agreement.After Julia died allegedly from injuries sustained during a series of mishaps at LCCC Rick filed this complaint stating claims of negligence and premises liability against Defendant. Defendant filed a motion to compel arbitration. The court granted the motion. The Supreme Court reversed, holding (1) Julia's durable power of attorney for health care did not grant Rick express actual authority to sign the arbitration agreement; (2) Julia did not hold Rick out as having apparent authority to sign the agreement; and (3) Rick was not authorized to execute the arbitration agreement as Julia's "surrogate" under the Wyoming Health Care Decisions Act, Wyo. Stat. Ann. 35-22-401 through 416. View "Miller v. Life Care Centers of America, Inc." on Justia Law