Justia Wyoming Supreme Court Opinion Summaries

Articles Posted in Civil Procedure

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In 2014, Tana Brown filed a complaint seeking a divorce from Darold Brown. Six days later, the district court signed a proposed stipulated decree of divorce. Ten months later, Tana moved to vacate or modify the divorce decree. After trial was scheduled, a scheduling conference was held and resulted in the entry of a scheduling order. Tana then filed a motion for sanctions asserting that Darold had not complied with a deadline in the scheduling order. The district court granted the motion for sanctions, imposing the requested sanction of prohibiting Darold from presenting witness testimony or exhibits at trial. After a trial, the district court granted physical custody of the parties’ children to Tana and divided remaining property and debt. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in imposing sanctions. View "Brown v. Brown" on Justia Law

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Walker Inman executed an inter vivos trust and a last will and testament. After Mr. Inman died, Daralee Inman, his wife, petitioned the district court for probate of Mr. Inman’s estate. Two years after the probate was opened, Wyoming Trust Company (WTC) filed a petition seeking to be appointed as the conservator of the minor children in the probate action. The district court granted the petition. WTC, as conservator for the minor children, filed a separate complaint for declaratory relief and damages, together with a petition to remove trustees, alleging six causes of action. The cases proceeded simultaneously over the next two years. The district court later ordered the cases consolidated. The court then issued its decision and order, interpreting a trust provision and holding that the Wyoming Probate Code governs the transfer of property to the trust but making no final determination of either of the two consolidated matters. Daralee Inman appealed. The Supreme Court dismissed the appeal, holding that the Court lacked jurisdiction to decide the appeal because the order was not a final appealable order. View "In re Estate of Inman" on Justia Law

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Plaintiff, as personal representative of the Estate of Theodore Meiners, filed an action seeking enforcement of a divorce settlement agreement entered into between Theodore and his former wife, Colleen Meiners. The district court granted summary judgment to Colleen on some claims and to Plaintiff on other claims. The district court certified its ruling as final pursuant to Wyo. R. Civ. P. 54(b). Plaintiff appealed. The Supreme Court dismissed Plaintiff’s appeal, holding that the district court’s summary judgment ruling was not properly certified as a final, appealable order pursuant to Rule 54(b). Remanded with directions. View "Meiners v. Meiners" on Justia Law

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Appellees, the purported owners of the “Jay Ranch,” brought an action against Appellant to establish a private road across Appellant’s property. While this suit was pending, Appellees were involved in litigation to determine the rightful ownership the Jay Ranch. The district court concluded that Appellees had satisfied the statutory threshold requirements to move forward with their private road claim and granted Appellees temporary access to the road across Appellant’s property. Thereafter, a decision was rendered against Appellees in the litigation to determine ownership of the Jay Ranch. The district court subsequently dismissed the present case for lack of prosecution. Appellant filed a motion for an award of attorney’s fees and a motion for an award of compensation for the temporary road access. The district court denied both motions. The Supreme Court dismissed Appellant’s appeal, holding (1) Appellant’s post-judgment motion for attorney’s fees was not authorized under Wyo. R. Civ. P. 54; and (2) the district court did not have jurisdiction to consider Appellant’s motion for compensation. View "Edsall v. Moore" on Justia Law

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Three consolidated cases involved an ongoing dispute over personal property awarded to Megan Golden in her 2012 divorce from Todd Guion. Golden appealed the district court’s order that: (1) rejected her request for a rehearing on a 2012 denial of her motion to find Guion in contempt of court; (2) denied her motion to vacate a February 2015 order following contempt hearings; and (3) granted Guion’s request for sanctions under W.R.C.P. 11. After review, the Supreme Court dismissed two of the cases for lack of jurisdiction, and affirmed the sanctions case because Golden did not file not file timely notices of appeal. View "Golden v. Guion" on Justia Law

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Jeff Lokey and Mike Irwin were business partners in two Wyoming businesses. After the parties dissolved their shared business interests, Irwin filed suit against Lokey, alleging that Lokey had materially breached the terms of the agreement. When Lokey did not timely file an answer the district court entered a default judgment against Lokey that included a provision allowing the parties ten days to file objections to the judgment. Lokey filed an objection, which the district court denied. Lokey appealed, challenging the court’s denial of his objections. The Supreme Court dismissed the appeal, holding (1) the Court lacked jurisdiction to entertain the appeal because Lokey did not timely appeal an appealable order; but (2) the Court had jurisdiction to award, and Irwin was entitled to recover, reasonable attorney fees incurred as a result of this appeal. View "Lokey v. Irwin" on Justia Law

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Automation & Electronics, Inc. (A&E) and Consolidated Electric Distributors, Inc. (CE) sued for Red Desert Reclamation, LLC for amounts due on their respective contracts. Pursuant to a stipulation between A&E and Red Desert, the district court entered judgment in favor of A&E. CE was later voluntarily dismissed from the case. A&E subsequently filed a motion for leave to amend its complaint to add CSC Group Holdings, LLC and Cate Street Capital, Inc. as defendants and to add alter ego and fraudulent conveyance claims. The district court granted the motion to amend. The district court then entered two default judgments in favor of A&E making CSC, Cate Street and Red Desert jointly and severally liable on Red Desert’s debt to A&E and setting aside as fraudulent a mortgage granted by Red Desert to CSC, thereby allowing A&E to execute on real property to recover on its judgment against Red Desert. The Supreme Court affirmed, holding that the district court did not lose subject matter jurisdiction over A&E’s motion to amend its complaint after signing off on the stipulated judgment in its favor because A&E was allowed to amend its complaint before CE was voluntarily dismissed from the action. View "CSC Group Holdings, LLC v. Automation & Electronics, Inc." on Justia Law

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At the heart of these three consolidated appeals was Sky Harbor’s alleged failure to pay rent to the Cheyenne Regional Airport and to leave the Airport premises. Sky Harbor argued that the district court lacked subject matter jurisdiction to decide any of the cases now on appeal. The district court generally ruled in favor of the Airport in all three cases. The Supreme Court affirmed, holding (1) the district and circuit courts did not lack subject matter jurisdiction in the three combined appeals; and (2) the judgments were entered in accordance with the law. View "Sky Harbor Air Serv., Inc. v. Cheyenne Reg’l Airport Bd." on Justia Law

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This matter arose following the Supreme Court’s opinion in Wallop Canyon Ranch, LLC v. Goodwyn, in which the Supreme Court affirmed a district court order awarding Scott Goodwyn attorney fees pursuant to Wyo. Stat. Ann. 17-14-1104. Goodwyn subsequently filed a motion to recover appellate attorney fees. The district court denied the application, concluding that Goodwyn was required to file his motion with the Wyoming Supreme Court before the mandate issued. The Supreme Court dismissed Goodwyn’s appeal on the merits, holding that the district court’s order denying Goodwyn’s motion for appellate attorney fees was a correct application of the law. View "Goodwyn v. Wallop" on Justia Law

Posted in: Civil Procedure

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In 2014, Appellant filed a Wyo. R. Civ. P. 60(b)(4) motion seeking to set aside a 1999 default judgment granting Appellee a divorce. In support of her motion, Appellant alleged that the default judgment was void because the district court lacked jurisdiction to enter the default judgment against her. The circuit court denied the motion, finding that the motion was not filed within a reasonable time. The Supreme Court affirmed, holding (1) the district court erred in rejecting Appellant’s Rule 60(b)(4) motion based solely on Appellant’s delay in filing the motion, as Rule 60(b)’s time limitations do not generally apply to Rule 60(b)(4) motions to set aside a judgment as void; but (2) none of the defects Appellant alleged in the district court’s default judgment rendered the judgment void for lack of jurisdiction. View "Linch v. Linch" on Justia Law