Justia Wyoming Supreme Court Opinion Summaries

Articles Posted in Civil Procedure

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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 dismissing Finley Resources, Inc.'s complaint against EP Energy E&P Company on the grounds that the forum-selection clause contained in the contract between the parties required Finley to file its suit in Texas, holding that the district court did not abuse its discretion in declining to exercise jurisdiction based on the forum-selection clause. On appeal, Finley argued that the district court abused its discretion in dismissing Finley's lawsuit because the declaratory judgment, quiet title, and adverse possession claims did not arise from the parties' contract and, even if the equitable causes of action arose from the contract, the Texas courts lacked subject matter jurisdiction to consider the claims. The Supreme Court disagreed, holding (1) Finley's equitable claims were matters in connection with the contract and were subject to the forum-selection clause; and (2) Finley's claims will necessarily be resolved by the Texas court's determination of its contractual rights. View "Finley Resources, Inc. v. EP Energy E&P Co." on Justia Law

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The Supreme Court affirmed the decision of the district court dismissing Appellants’ Wyo. R. Civ. P. 60 motion to set aside the coroner’s inquest verdict, holding that the district court does not have subject matter jurisdiction in a post-coroner inquest proceeding. Nearly four months later after Lee Birkholz died, the Teton County Coroner conducted a coroner’s request and presented Birkholz’s toxicology results to the inquest jury. The proceeding resulted in a coroner’s inquest verdict of “death due to aspiration secondary to alcohol and 5-methoxy-DMT ingestion.” Appellants filed the Rule 60 motion to set aside the inquest verdict. The coroner moved to dismiss the Rule 60 motion for lack of subject matter jurisdiction. The district court granted the motion to dismiss. The Supreme Court affirmed, holding that the coroner’s inquest verdict is not a final order and has no probative effect and that the filing of the coroner’s inquest verdict with the district court is ministerial and does not confer jurisdiction on the district court. View "Cassidy v. Teton County Coroner" on Justia Law

Posted in: Civil Procedure

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The Supreme Court reversed the order of the district court dismissing Plaintiff’s medical malpractice suit against Defendant because Defendant was not served with the complaint and summons within ninety days after the case was filed pursuant to Wyo. R. Civ. P. 4(w), holding that the district court abused its discretion in dismissing Plaintiff’s complaint. In dismissing the complaint, the district court determined that Plaintiff had not established good cause for a mandatory extension of time to serve Defendant. Specifically, the court concluded that while Plaintiff had shown equitable factors in favor of permissive extension, the court would not grant such an extension due to prior procedural problems caused by Plaintiff’s counsel. The Supreme Court reversed, holding (1) the record supported the district court’s finding that Plaintiff did not establish good cause; but (2) the district court abused its discretion by imposing additional consequences on Plaintiff for his counsel’s failures in other areas. View "Oldroyd v. Kanjo" on Justia Law

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The Supreme Court dismissed Mother’s appeal from the district court’s denial of Mother’s motion for an ex parte order granting her emergency custody of her two children, holding that Mother’s motion was not an appealable order. Father was awarded custody of the parties’ two children following the parties’ divorce. Mother later filed a motion for an ex parte order granting her emergency custody of the children, alleging, among other things, that Father was alienating the children from her. The district court denied the motion, and Mother appealed. The Supreme Court dismissed the appeal, holding that it lacked jurisdiction because the order resolved only the issue of temporary custody. Further, the Court found that Husband was entitled to his reasonable attorney fees and costs of responding to this appeal. View "Wood v. Wood" on Justia Law

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At issue was whether this case presented a justiciable issue when the Supreme Court could not render a decision binding on a federal agency and could only offer an advisory opinion that may or may not ultimately bind the parties. Berenergy Corporation, which produced oil from several sites under oil and gas leases granted by the United States Department of the Interior, Bureau of Land Management (BLM), sought a declaratory judgment that the terms of its BLM oil leases provided it with rights superior to any obtained by Peabody Energy Corporation through its coal leases. The district court granted in part and denied in part both parties’ motions for summary judgment. Both parties appealed. The Supreme Court remanded the case for further proceedings before the district court, holding (1) Congress intended that the issues raised by Berenergy be decided by the Secretary of the Interior or its BLM designees; (2) there was no express consent by the federal government for the Secretary or the BLM to be made a party to suits such as this for the purpose of informing a congressionally approved decision by the district court; but (3) the court nonetheless remands this case for an evaluation of whether a federal agency may participate in this suit. View "Berenergy Corp. v. BTU Western Resources, Inc." on Justia Law

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The Supreme Court affirmed the judgment of the district court dismissing Appellant’s declaratory judgment action for lack of a justiciable controversy. Appellant’s driver’s license was suspended after her agreed to take a breath test and provided a breath sample indicating his blood alcohol concentration to be over the legal limit. Appellant initiated a civil action seeking a declaratory judgment that the Wyoming Constitution prohibits a law enforcement officer from using the “deemed consent” provision of Wyo. Stat. Ann. 31-6-102(a)(i) to perform a warrantless chemical test incident to the lawful arrest of a motorist. The district court concluded that the request did not present a justiciable controversy and granted the Wyoming Department of Transportation’s motion to dismiss the action. The Supreme Court affirmed, holding that the district court properly dismissed the claim because Appellant failed to present a justiciable controversy. View "Leavitt v. State, ex rel. Wyoming Department of Transportation" on Justia Law

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The Supreme Court summarily affirmed the district court’s order recognizing and adopting the settlement Richard Hodson reached with Janet Sturgeon. In the settlement, the parties agreed to resolve their pending lawsuit and to divide their jointly owned property. Hodson challenged the district court’s order adopting the settlement through this pro se appeal, apparently arguing that the district court erred in refusing to enforce an agreement that allegedly existed before he filed his lawsuit. The Supreme Court held that Hodson failed to comply with the court’s rules of appellate procedure, and therefore, summarily affirmed the district court’s order. The court also granted Sturgeon’s request for an award of costs and attorney fees. View "Hodson v. Sturgeon" on Justia Law

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The Supreme Court dismissed Appellant’s appeal from the district court’s order dismissing the Wyoming Department of Workforce Services Labor Standards Appeals Division (WFS) from Appellant’s petition for review of a WFS hearing examiner’s decision denying Appellant’s request for damages on his claim that the Wyoming Department of Corrections (DOC) discriminated against him based upon his advanced age. The district court granted WFS’s motion to dismiss, concluding that WFS was not a proper respondent to the petition for review. Several months later, the district court denied Appellant’s motion to amend his petition for review to substitute or join DOC as respondent in the action, ruling that it had no jurisdiction to act on Appellant’s motion to amend because the case was finally resolved upon WFS’s dismissal. On appeal, the Supreme Court concluded that it did not have jurisdiction over this matter because the district court’s order dismissing WFS was final and appealable. View "Schmitz v. State, Department of Workforce Services" on Justia Law

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Nikki Jo Burtsfield died in a law enforcement shooting. The county coroner examined the body and prepared the verdict and case docket, listing the manner and cause of death. Appellant filed a public records request with the coroner seeking disclosure of the verdict and case docket. Dissatisfied with the documents he received in response to his request, Appellant filed a “Motion for Reasonable Response” with the district court, requesting that the court order the coroner to produce a case docket of “sufficient detail.” The district court dismissed the action pursuant to Wyo. R. Civ. P. 12(c). The Supreme Court affirmed, holding (1) Appellant was actually requesting relief in mandamus, and even though he did not follow the pleading requirements, the district court had jurisdiction over the action; and (2) on the merits, while the district court erred in denominating its decision as a dismissal under Rule 12(c) rather than a summary judgment, its decision was correct because the coroner did not have an absolute, clear and indisputable duty to provide the detailed information requested by Appellant. View "Williams v. Sundstrom" on Justia Law