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The Supreme Court affirmed Defendant’s felony conviction for taking a controlled substance into a jail under Wyo. Stat. Ann. 6-5-208. That statute provides, in pertinent part, that “[e]xcept as authorized by a person in charge, a person commits a felony…if that person takes or passes any controlled substance or intoxicating liquor into a jail[.]” The Supreme Court affirmed, holding (1) an arrestee can voluntarily take controlled substances into a jail; (2) the booking area is part of the jail; and (3) the prosecutor’s closing argument did not violate Defendant’s rights under the Fifth Amendment. View "Barrera v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed in part and reversed in part the district court’s grant of summary judgment in favor of Peak Powder River Resources, LLC (Peak) and against Bear Peak Resources, LLC (Bear) in this action alleging breach of contract, among other claims. Bear and Peak had agreed to work together in acquiring mineral interests for development, but Peak later obtained some mineral interests without compensating Bear and terminated the parties’ agreement. Bear filed suit. The district court determined that Peak was entitled to summary judgment on all of Bear’s claims. The Supreme Court reversed in part, holding that the district court (1) properly granted Peak’s motion for summary judgment on Bear’s breach of the implied covenant, breach of fiduciary duty, and accounting claims; (2) properly concluded that the parties’ contract was unambiguous; and (3) did not err in determining that Peak was entitled to summary judgment on several of the individual breach of contract claims, but genuine issues of material fact existed on the remaining claims. View "Bear Peak Resources, LLC v. Peak Powder River Resources, LLC" on Justia Law

Posted in: Contracts

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The Supreme Court reversed the district court’s order denying Kindred Nursing and Rehabilitation - Wind River’s motion to compel arbitration in this wrongful death action. Aletha Boyd died following her discharge from Kindred. Aletha’s daughter, Susan Boyd, filed this action alleging that Kindred’s negligence in caring for Aletha caused her death. Kindred moved to compel arbitration pursuant to an alternative dispute resolution (ADR) agreement signed by Leanna Putman, Aletha’s other daughter and representative under a power of attorney at the time of Aletha’s admission into the nursing home. The district court denied the motion without providing reasons for doing so. The Supreme Court remanded with instructions to order arbitration as required by the ADR agreement, holding (1) Putnam had the authority to sign the ADR agreement on Aletha’s behalf; and (2) the ADR was neither unconscionable nor lacked mutuality of assent or sufficient consideration. View "Kindred Heathcare Operating, Inc. v. Boyd" on Justia Law

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The Supreme Court affirmed Defendant’s conviction for interfering with a peace officer, in violation of Wyo. Stat. Ann. 6-5-204(b). The statute provides that “[a] person who intentionally and knowingly causes or attempts to cause bodily injury to a peace officer engaged in the lawful performance of his duties is guilty of a felony[.]” On appeal, Defendant argued that the evidence was insufficient to sustain his conviction because there was insufficient evidence that he intentionally kicked the peace officer and that he caused bodily injury to the officer. In affirming Defendant’s conviction, the Supreme Court held that the State provided sufficient evidence to support its charge that Defendant intentionally and knowingly caused bodily injury to the officer. View "Flores v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the judgment of the district court finding that a California court probate order distributing the estate of Lon V. Smith and a Wyoming court probate order to distribute the decedent’s Wyoming property, including a Carbon County overriding royalty interest (ORRI), governed, regardless of Mr. Smith’s intent as expressed in his will. In his will, Smith intended for the ORRI to be distributed to his wife, Marguerite B. Smith, for her life, and then to be distributed to the Lon V. Smith Foundation. The probate court orders distributed the ORRI to Mrs. Smith under the will’s residuary clause. The district court ruled that the Marguerite Brown Smith Trust (the beneficiary under Mrs. Smith’s will) owned the ORRI, not the Foundation. The Supreme Court affirmed, holding that the district court (1) correctly determined that the California probate order and the Wyoming ancillary probate ordered governed and that the Trust was the owner of the ORRI; (2) properly granted summary judgment to Devon Energy Corporation and Devon Energy Production Co. (collectively, Devon) on the Foundation’s claim that Devon violated the Wyoming Royalty Payment Act (WRPA); and (3) correctly found that neither party was entitled to attorney fees under the WRPA. View "Lon V. Smith Foundation v. Devon Energy Corp." on Justia Law

Posted in: Trusts & Estates

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The Supreme Court affirmed the district court’s decision affirming the decision of the Medical Commission, which sustained the Wyoming Workers’ Compensation Division’s termination of Sarah Morris’s temporary total disability (TTD) benefits. The Division terminated the TTD benefits after determining that Morris had reached maximum medical improvement. The Supreme Court held (1) the Commission appropriately determined that Morris had reached MMI and terminated her TTD benefits; and (2) substantial evidence existed to support the Commission’s decision that Morris’s injury to her right knee was not work-related. View "Morris v. State ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

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The district court did not abuse its discretion when it awarded primary physical custody of the parties’ daughter to Father. After Mother and Father divorced, Mother remarried and announced her intent to relocate to southern Colorado. Both parties sought primary physical custody of their daughter. The district court found that the child’s best interests were served by Father having primary custody. The Supreme Court affirmed, holding (1) the district court’s findings provided the court with a reasoned explanation for the district court’s decision to separate the child from her siblings; and (2) the district court did not err in admitting into evidence two letters written by Mother’s older child describing the child’s complaints about her relationship with Mother and recounting various instances of conflict. View "Paden v. Paden" on Justia Law

Posted in: Family Law

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The Supreme Court affirmed the district court’s dismissal of a complaint brought by the Town of Pine Bluffs alleging that Laramie County illegally taxed a day care center that the Town owned and operated. The Town sought an injunction under Wyo. Stat. Ann. 39-13-109(c)(i), alleging that the property was used for a governmental purpose and was therefore exempt under Wyo. Stat. Ann. 39-11-105(a)(v). The district court granted the County’s motion to dismiss, concluding that the Town should have exhausted administrative remedies before resorting to an injunction. The Supreme Court affirmed, holding that section 39-13-109(c)(i) did not provide the Town a remedy for an error in assessing the day care center and that it needed to resort to the administrative process instead. View "Town of Pine Bluffs v. Eisele" on Justia Law

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Due to deficiencies in this pro se appeal filed by Appellant, the Supreme Court summarily affirmed the district court’s dismissal of Appellant’s complaint. Appellant, a former project engineer at Sinclair Wyoming Refining Company, filed a complaint against certain Sinclair defendants, asserting fraud in the inducement and execution, breach of contract, and malicious destruction of property. The Sinclair defendants filed a motion to dismiss. Appellant filed timely to respond to the motion. The district court granted the motion to dismiss without a hearing. The Supreme Court summarily affirmed, holding that Appellant did not adequately comply with the Wyoming Rules of Appellate Procedure. View "Cor v. Sinclair Services Co." on Justia Law

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The Supreme Court affirmed the decision of the Teton County Board of County Commissioners granting Four Shadows, LLC a basic use permit (BUP) to use its property in Teton Village for temporary construction storage/staging. The court held (1) Appellants had an interest that was greater than the general public’s, giving them standing to maintain their appeal as persons aggrieved and adversely affected in fact by the Board’s decision to issue the permit; and (2) the Board’s decision to grant Four Shadows a BUP for temporary use of the property for construction storage/staging was not arbitrary, capricious, an abuse of discretion, or otherwise contrary to law. View "Tayback v. Teton County Board of County Commissioners" on Justia Law