Justia Wyoming Supreme Court Opinion Summaries

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The Supreme Court affirmed in part and reversed in part the judgment of the district court, on a motion for judgment on the pleadings, resolving disputed questions of material fact concerning the propriety of Petitioner's proposed decanting of trust property, holding that the court properly concluded that Petitioner had the general authority to decant the trust property but erred in resolving disputed factual issues concerning the appropriateness of the proposed decanting. Petitioner, as trustee of a trust, filed a petition for instructions asking the district court to confirm its general authority to decant trust property under Wyoming law and the trust agreements and further sought approval of its proposal to decant the trust's property into two separate trusts. The district court granted Petitioner's motion for judgment on the pleadings, concluding that decanting was permissible. The court, however, also resolved disputed questions of material fact concerning the propriety of Petitioner's proposed decanting. The Supreme Court reversed in part, holding that the district court's order went beyond the discrete legal question of whether Petitioner had the general authority to decant trust property. View "Evertson v. Evertson Fiduciary Management Corp." on Justia Law

Posted in: Trusts & Estates

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The Supreme Court affirmed the decision of the district court terminating Mother's parental rights to three of her minor children pursuant to Wyo. Stat. Ann. 14-2-309(a)(iii) and (v), holding that the evidence was sufficient to support the court's determination. While the district court found clear and convincing evidence supported termination of Mother's parental rights under both section 14-2-309(a)(iii) and (v) the Supreme Court needed determine only whether clear and convincing evidence supported one of the bases for termination. The Court affirmed the district court's finding of clear and convincing evidence to support termination under section 14-2-309(a)(v), holding that the district court's decision finding Mother unfit was supported by clear and convincing evidence. View "Dunlap v. State, Department of Family Services" on Justia Law

Posted in: Family Law

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The Supreme Court reversed the order of the district court dismissing Appellant's divorce action against Appellee on the grounds of improper venue and/or forum non conveniens, holding that the district court erred by dismissing the action for improper venue and did not apply the correct test when it dismissed for forum non conveniens. The parties married in North Carolina in 1989. In 2018, Appellant filed a complaint for divorce in the district court in Fremont County, Wyoming, where he lived. Appellee filed a motion to dismiss the Wyoming action pursuant to Wyo. R. Civ. P. 12(b)(3), claiming that Wyoming was an improper venue for the divorce and/or forum non conveniens. The district court granted Appellee's motion. In doing so, the court followed the Supreme Court's decision in West Texas Utilities Co. v. Exxon Coal USA, Inc. 807 P.2d 932 (Wyo. 1991). The Supreme Court reversed, holding that the district court's analysis was inadequate. Consequently, the Court adopted the two-stage test for forum non conveniens from Gulf Oil Corp. v. Gilbert, 330 U.S. 501 (1947), and directed the district court to apply that test on remand. View "Saunders v. Saunders" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree sexual abuse of a minor, holding that Defendant was not entitled to relief on any of his allegations of error. Defendant was charged with three counts of first-degree sexual abuse of a minor. Defendant was convicted on counts I and III and acquitted on count II. Defendant appealed his conviction on count I, claiming, among other things, that the trial court committed reversible error because the jury instructions contained identical elements for counts I and II with nothing to differentiate the counts and because the verdict form also failed to distinguish between the two counts. The Supreme Court reversed, holding (1) Defendant waived review of his challenge regarding the description of counts I and II under the invited error doctrine; (2) the evidence was sufficient to convict Defendant on count I; and (3) Defendant's counsel was not ineffective. View "Jackson v. State" on Justia Law

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The Supreme Court affirmed the decision of the district court granting the State's motion to vacate an order granting Appellant relief from the requirement to register as a sex offender and reviving Appellant's registration requirement, holding that the district court did not abuse its discretion when it granted the State's motion for relief. Appellant petitioned the district court to terminate his duty to register as a sex offender, claiming that he met the statutory requirements under Wyo. Stat. Ann. 7-19-304(a)(i). The district court granted the petition. Thereafter, the State filed a Wyo. R. Crim. P. 60 motion alleging that Appellant was not eligible for relief from the duty to register. The district court granted the motion, finding that Appellant was not statutorily eligible for termination because he was convicted of incest as an adult and not adjudicated as a delinquent. The Supreme Court affirmed, holding that the district court's order granting the State's motion to vacate the judgment relieving Defendant from the sex offender reporting requirement was an appropriate exercise of judicial discretion. View "Gunsch v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of possession of methamphetamine, holding that the district court's statements to the jury did not constitute reversible error and that the evidence was sufficient to support the conviction. During trial, the district court advised the jury that they might want to wear gloves before examining the evidence of a baggie containing the methamphetamine. On appeal, Defendant argued that the district court's remarks about the evidence were error per se or, in the alternative, plain error and that the evidence was insufficient to establish the "knowledge" element of the crime. The Supreme Court affirmed, holding (1) the district court did not inject bias into the proceedings or interfere with the jury's fact-finding role, and even if the statements in question were in error, Defendant failed to demonstrate material prejudice to a substantial right; and (2) there was sufficient evidence to support a guilty verdict beyond a reasonable doubt. View "Sorensen v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of aggravated assault and battery, driving under the influence of a controlled substance, and unlawful use of a toxic substance, holding that the district court did not err in convicting Defendant for aggravated assault and battery. Specifically, the Court held (1) the "knowingly" requirement of Wyo. Stat. Ann. 6-2-501(a)(ii) did not require the State to prove that Defendant purposefully hit the victim's vehicle, but rather, Defendant's knowing and voluntary act of continuing to drive while under the influence of an inhalant provided the required mens rea to impose criminal liability for aggravated assault and battery under the statute; (2) the evidence was sufficient to support Defendant's conviction; and (3) the district court properly instructed the jury as to the statutory elements. View "Hopkins v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the judgment of the district court revoking the liquor license held by the Mattheis Company (Company), holding that the district court correctly determined that The Mattheis Company committed a gross violation of Title 12. See Wyo. Stat. Ann. 12-1-101 to 12-10-102. After learning that the Company, which operated a bar in Jackson, Wyoming, the Town of Jackson initiated proceedings to revoke the Company's liquor license. The district court revoked the Company's liquor license following a bench trial. The Supreme Court affirmed, holding (1) liquor-license revocation requires a "gross violation" of Title 12; (2) the district court did not err in concluding that the Company's submission of a false liquor license renewal application was a gross violation of Title 12, notwithstanding the Company's asserted reliance on the advice of counsel; and (3) the district court did not abuse its discretion in revoking the Company's liquor license rather than suspending it. View "Mattheis Co. v. Town of Jackson" on Justia Law

Posted in: Business Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of aggravated kidnapping, sexual abuse of a minor in the first degree, and sexual abuse of a minor in the second degree and sentencing Defendant to a term of eighty to 115 years in prison, holding that Defendant's claims of error were unavailing. Specifically, the court held (1) the district court did not err in denying Defendant's motion for a new trial because Defendant failed to show that his trial counsel was constitutionally ineffective; (2) the district court did not abuse its discretion in admitting other acts evidence under Wyo. R. Evid. 404(b); (3) there was sufficient evidence to sustain Defendant's aggravated kidnapping conviction; and (4) double jeopardy principles did not require the aggravated kidnapping and first-degree sexual abuse of a minor sentences to be merged. View "Winters v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting and sentencing Defendant for misdemeanor theft and felony property destruction, holding that Defendant was not entitled to relief on any of his assignments of error. Specifically, the Court held (1) the prosecutor did not commit misconduct by not controlling three of the state's witnesses, who provided non-responsive answers to certain questions, holding that there was no misconduct; (2) Defendant was not entitled to a judgment of acquittal on the charge of theft or on the charge of property destruction; and (3) the district court did not abuse its discretion in awarding $2,500 in restitution after the jury convicted Defendant of misdemeanor theft. View "Kuebel v. State" on Justia Law

Posted in: Criminal Law