Justia Wyoming Supreme Court Opinion Summaries

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The Supreme Court affirmed Defendant's conviction of felony possession of marijuana, entered following Defendant's conditional guilty plea, holding that the initial traffic stop of Defendant in this case comported with the requirements of the Fourth Amendment to the United States Constitution.In denying Defendant's motion to suppress, the trial court concluded that the initial traffic stop was justified as a drug trafficking investigation. Defendant appealed, arguing that the district court erred in concluding the officer had reasonable suspicion to stop Defendant based on the collective knowledge doctrine. The Supreme Court affirmed, holding that the initial stop was legally justified under the Fourth Amendment, and therefore, the district court did not err in denying Defendant's motion to suppress. View "Guandong v. State" on Justia Law

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The Supreme Court affirmed the judgment of the Wyoming Workers' Safety and Compensation Division denying coverage for Claimant's thoracic spine treatment, holding that the Medical Commission's decision was supported by the hearing evidence.After the Division denied Claimant's compensation coverage for his thoracic spine treatment Claimant appealed. The Compensation Commission upheld the denial of coverage following a contested pain hearing, and the district court affirmed. The Supreme Court affirmed, holding (1) the record contained substantial evidence to support the Commission's findings that Claimant's thoracic spine injury was unrelated to his work-related accident; and (2) Claimant failed to meet his burden of proving that his thoracic spine evaluation and treatment were compensable under the "rule out" doctrine. View "Hart v. State of Wyoming, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

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The Supreme Court reversed the order of the district court granting summary judgment in favor of Defendant on her counterclaim for breach of contract in this legal malpractice lawsuit, holding that there was a genuine issue of material fact as to whether the parties entered into a lawfully enforceable settlement agreement.The underlying lawsuit arose after the death of Plaintiff's mother when Defendant failed timely to file an application with the Wyoming Medical Review Panel and a wrongful death lawsuit. Defendant filed a counterclaim for breach of contract, alleging that the parties had entered into a valid agreement to settle the legal malpractice claim for $100,000. The district court granted summary judgment in favor of Defendant, concluding that the settlement agreement was enforceable. The Supreme Court reversed, holding that there was a genuine issue of material fact about whether the parties had a setting of the funds on the issue of who was settling and who would be bound by the settlement, precluding summary judgment. View "Kappes v. Rhodes" on Justia Law

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The Supreme Court affirmed the judgment of the probate court denying the motion for an order to show cause filed by Cynthia Soames, the personal representative of her brother's estate, against Dick Gifford, the estate's previous personal representative, holding that the probate court did not err.In her motion, Soames argued that certain items went missing from the estate while Gifford was personal representative and requesting that Gifford account for those items. The probate court denied the motion after a hearing, thus declining to hold Gifford in contempt, finding that Gifford's testimony was credible and that Soames did not meet her burden of proving that Gifford took and failed to return the items. The Supreme Court affirmed, holding that the court did not err when it determined that Gifford's testimony was credible. View "Soares v. Gifford" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court affirmed in part and reversed in part the decision of the district court granting summary judgment to Family Tree Corporation and JD4, LLC (collectively, Family Tree) and dismissing Skyco Resources, LLP's complaint asserting claims for breach of contract, breach of the covenant of good faith and fair dealing, conversion, and fraud/intentional misrepresentation, holding that the district court erred in part.Skyco entered into an agreement with Family Tree for the purchase of mineral interests owned by Family Tree. Before closing, however, Skyco wrote a letter giving notice of its termination of the agreement and demanding a return of its earnest money. Because Skyco failed to comply with the agreement's termination provision Family Tree refused to return the earnest money. Skyco then sued for return of the earnest money. The district court granted summary judgment to Family Tree. The Supreme Court reversed in part, holding that the district court (1) erred in granting summary judgment for Family Tree on Skyco's claim for return of its earnest money; and (2) properly granted summary judgment for Family Tree on Skyco's remaining claims. View "Skyco Resources, LLP v. Family Tree Corp." on Justia Law

Posted in: Contracts
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The Supreme Court dismissed Mother's appeal from two juvenile court permanency and review orders and from the juvenile court's decision denying her motion to close the case for want of jurisdiction, holding that none of the juvenile court orders from which Mother appealed were appealable orders.The State filed a neglect petition alleging that Mother neglected her child. As the case progressed, the juvenile court held review and permanency hearings, in connection with which it issued orders. Mother appealed two of those orders and the denial of her motion to close the case. The Supreme Court dismissed the appeal, holding that the orders appealed from did not affect Mother's substantial rights and were not appealable. View "JW v. State" on Justia Law

Posted in: Family Law
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The Supreme Court affirmed Defendant's conviction of sexual abuse of a minor in the second degree, holding that Defendant failed to establish that the district court committed plain error by allowing certain testimony.On appeal, Defendant argued that plain error occurred during trial when the district court allowed State witnesses to vouch for the credibility of other State witnesses and/or to offer opinions as to Defendant's guilt. The Supreme Court disagreed and affirmed, holding (1) the State's witnesses did not vouch for the credibility of other witnesses or offer opinions as to Defendant's guilt; and (2) in the absence of any error, the cumulative error doctrine did not apply. View "Ingersoll v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the district court denying Diana Myers's Wyo. R. Crim. P. 60(b)(6) motion seeking relief from the parties' martial settlement agreement and divorce decree, holding that the district court did not abuse its discretion.In 2019, Diana and Griffin Myers divorced. In 2021, Diana filed her motion seeking relief from the settlement agreement and divorce decree on the grounds that an asset divided pursuant to the divorce was worth significantly more than Diana believed during mediation. The district court denied the motion. The Supreme Court affirmed, holding (1) Diana had no right to discovery on her Rule 60(b) motion; and (2) the district court did not abuse its discretion when it concluded that Diana's motion asserted improper grounds, was untimely, and failed to demonstrate extraordinary circumstances. View "Myers v. Myers" on Justia Law

Posted in: Family Law
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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 there was no error.Defendant was convicted of three counts of first-degree sexual assault, one count of kidnapping, and one count of aggravated assault and battery. The Supreme Court affirmed on direct appeal. Defendant later filed his motion to correct an illegal sentence, asserting that his sentence violated constitutional prohibitions against double jeopardy. The district court denied relief, determining that Defendant's claims were barred by res judicata and failed on the merits. The Supreme Court affirmed, holding that Defendant's motion to correct an illegal sentence was barred by res judicata. View "Harrell v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence obtained after law enforcement entered her home without a warrant or consent, holding that the district court erred.Defendant entered a conditional plea of guilty to felony driving under the influence. On appeal, Defendant challenged the district court's denial of her motion to suppress, arguing that the record did not support a finding that her husband consented to a law enforcement officer's entry into their home. The Supreme Court reversed and remanded the case, holding (1) the district court erred in concluding that the officer had implied consent to enter the home; and (2) therefore, the officer violated the Fourth Amendment to the United States Constitution. View "Hawken v. State" on Justia Law