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The Supreme Court affirmed the judgment of the district court dismissing Appellant's pro se complaint filed under the Declaratory Judgment Act alleging that the Wyoming Department of Corrections (WDOC) violated certain policies and procedures during disciplinary proceedings brought against him, holding that Appellant was not entitled to relief. Specifically, the Court held (1) Appellant did not have standing to seek a general declaration that the WDOC must abide by its own rules and regulations, and the district court properly considered standing in dismissing Appellant's complaint even though the WDOC did not raise the standing issue in its motion to dismiss; and (2) collateral estoppel and res judicata barred Appellant's claims that procedural violations occurred during his disciplinary proceedings. View "Bird v. Lampert" on Justia Law

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The Supreme Court affirmed the order of the district court entering partial summary judgment against Rex Rammell on all his claims against his former employer, Mountainaire Animal Clinic, P.C., its president, and its office manager except Rammell's breach of express contract claim and then dismissing that claim as a sanction for willful obstruction of discovery and fraud upon the court, holding that the district court did not err. Specifically, the Court held (1) deficiencies in Rammell's certification did not mandate dismissal of his appeal; (2) defects in Rammell's notice of appeal did not mandate dismissal; (3) the district court did not err in entering summary judgment against Rammell on his tortious interference claim; and (4) the district court did not abuse its discretion in dismissing Rammell's breach of express contract claim as a sanction for discovery violations. View "Rammell v. Mountainaire Animal Clinic, P.C." on Justia Law

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In this appeal brought by Alex Mantle and Marjorie Mantle the Supreme Court affirmed in part and reversed and remanded in part the district court's decision as to various post-trial issues in ongoing litigation arising from a soured business deal. The Court held (1) the district court lacked subject matter jurisdiction to offset the judgments when that issue was pending in the Supreme Court in Mantle I; (2) with respect to Killmer Settlement Funds, (a) there was no reviewable order in the record regarding whether the Garlands had standing to assert a direct claim against Karl Killmer, and (b) the Mantles did not have a superior security interest in the Killmer Settlement Funds by operation of the “general intangibles” clause of the FNB security agreement; (3) the district court did nor when it awarded North Star Energy & Construction, LLC's attorneys, The Kuker Group, their attorney fees from a portion of the Killmer Settlement Funds; and (4) the district court did not err when it issued a nunc pro tunc order that removed Marjorie Mantle’s name from the order that disbursed the Killmer Settlement Funds. View "Mantle v. North Star Energy & Construction LLC" on Justia Law

Posted in: Business Law, Contracts

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The Supreme Court reversed the order of district court awarding primary custody of the parties' two children and child support to Mother, holding that the district court abused its discretion by ordering child support without obtaining sufficient information about Father's income. Specifically, the Court held (1) the district court abused its discretion when it calculated the amount for child support based on a misunderstanding of the evidence establishing Father's income; and (2) Father's argument that the district court's time limits for presenting at trial deprived him of a meaningful opportunity to testify and cross-examine witnesses failed because Father's assertions were insufficient to explain how the district court's restriction on the time he had violated due process or his fundamental right to associate with his children. View "Lemus v. Martinez" on Justia Law

Posted in: Family Law

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The Supreme Court reversed Defendant's conviction for one count of incest, holding that the district court abused its discretion by permitting the State to use an expert to vouch for the credibility of the alleged victim, AS. On appeal, Defendant argued that the district court erred by allowing AS's counselor to testify that the "underlying basis" of AS's PTSD was her "reported sexual abuse." The Supreme Court affirmed, holding (1) the challenged testimony did more than "incidentally bolster" the credibility of AS; and (2) absent that testimony, there was a reasonable probability that Defendant would have enjoyed a more favorable verdict. View "Spence v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed Defendant's conviction of second degree sexual abuse of a minor, third degree sexual abuse of a minor, and contributing alcohol to a minor, holding that the district court did not abuse its discretion in ordering joinder of the sexual abuse charges relating to two victims and did not err in excluding evidence of a prior false sexual abuse allegation by one of the victims. Specifically, the Court held (1) there was no abuse of discretion in the district court's joinder of the offenses for trial where the court reasonably concluded that joinder of the sexual abuse charges was proper under Wyo. R. Crim. P. 8 and 13 and Defendant failed to show that he was prejudiced by the joinder; and (2) the district court did not abuse its discretion or infringe on Defendant's confrontation rights or his right to present a complete defense when it concluded that the victim's prior false statement was not admissible under the rape shield statute. View "Sparks v. State" on Justia Law

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The Supreme Court affirmed the district court's denial of Defendant's motion to suppress, thus affirming Defendant's conviction and sentence, holding that the warrantless detention of Defendant did not violate the Fourth Amendment or Wyo. Const. art. I, 4, 6 and 36. Defendant entered a conditional guilty plea to the charge of possession of marijuana. On appeal, Defendant argued that a police officer unlawfully detained him because he was not violating any laws as he was traveling down the highway and was stopped only pursuant to a temporary roadblock. Defendant asserted that the roadblock was illegal because the officer failed to comply with the statutory requirements set forth in Wyo. Stat. Ann. 7-17-101 through 7-17-103 and that the roadblock otherwise failed to comport with Fourth Amendment standards. The Supreme Court disagreed, holding that the district court properly found that the officer was directing traffic to sure public safety during a rodeo and that Defendant disobeyed the officer's signal to stop. Therefore, the initial stop was legally valid, and the odor of marijuana justified the subsequent search. View "Wright v. State" on Justia Law

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The Supreme Court dismissed this case in which Appellant sought judicial review of the administrative denial of his request for preauthorization for the purchase of several unique items to treat his work-related injury, holding that this Court lacked jurisdiction because Appellant filed his petition for review in a district court that did not have jurisdiction. The Wyoming Workers' Compensation Division denied Appellant's requests, and the Office of Administrative Hearings upheld the Division's determinations. Appellant filed a petition for review in the district court of the county where he was injured. The district court denied the Division's motion to dismiss and affirmed the OAH decision on the merits. The dismissed the action and vacated the district court's order, holding that the statute that provides for judicial review of the OAH decision, Wyo. Stat. Ann. 16-3-114(a), placed jurisdiction in the district court of the county where the administrative action was taken or the district court of the county where Appellant resided. View "McCallister v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

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The Supreme Court affirmed Defendant's conviction of three counts of second-degree sexual abuse of a minor and three counts of third-degree abuse of a minor, holding that the district court did not abuse its discretion in admitting the victims' prior consistent statements and that there was sufficient evidence to support Defendant's convictions for second-degree sexual abuse of a minor. On appeal, Defendant argued that the district court erred in admitting portions of the victims' Child Advocacy Project interview statements. The Supreme Court disagreed, holding (1) the district court did not abuse its discretion in admitting the prior consistent statements for rehabilitative purposes; and (2) there was sufficient evidence of sexual gratification to support Defendant's convictions for second-degree sexual abuse of a minor and that Defendant's argument concerning whether he touched one victim's "intimate parts" misstated the record. View "Jones v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court reversed Defendant's conviction of possession of methamphetamine, holding that Defendant's right to a speedy trial under Wyo. R. Crim. P. 48 was violated when the State failed to bring him to trial within 180 days following his arraignment. On appeal, Defendant argued that his right to a speedy trial was violated and that the trial court erred when it denied his motion to suppress the methamphetamine found in a container inside his truck. The Supreme Court reversed on the speedy trial issue and thus did not address the motion to suppress, holding that Defendant's right to a speedy trial was violated when his trial commenced 194 days after his arraignment. View "Osban v. State" on Justia Law