Justia Wyoming Supreme Court Opinion Summaries

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

This case concerned a dispute regarding who was entitled to the proceeds of a retirement annuity contract. Plaintiff filed a complaint for declaratory judgment pursuant to the Uniform Declaratory Judgments Act claiming that she was entitled to the proceeds. The circuit court entered summary judgment in favor of Defendant. Plaintiff appealed. The district court did not reach the merits of the case, concluding that the circuit court lacked jurisdiction over the dispute because only a district court has jurisdiction over matters brought under the Declaratory Judgments Act, no matter the amount in controversy. The Supreme Court reversed, holding (1) a cause of action seeking declaratory relief can be within the jurisdiction of the circuit court so long as the circuit court has jurisdiction independent of the declaratory relief requested; and (2) in this case, the circuit court had jurisdiction independent of the declaratory relief sought, and therefore, the court had jurisdiction to decide the declaratory judgment claim. View "Best v. Best" on Justia Law

Accelerated Receivable Solutions (ARS) filed a creditor’s claim against the Estate of Margaret A. Hauf (Estate). The Estate rejected ARS’s claim, filed the notice of rejection in district court, and mailed the rejection notice to ARS via certified mail. The mailed notice was returned to the Estate unclaimed. Approximately four months later, counsel for ARS learned that the postal service had erroneously stamped the the certified mailing unclaimed and returned it to the sender. ARS filed a complaint in district court objecting to the disallowance of its claim and seeking judgment on the claim. The district court dismissed the complaint as time barred. The Supreme Court affirmed, holding that the district court did not err in dismissing ARS’s complaint against the Estate where the Estate strictly complied with the statutory notice requirements in rejecting ARS’s claim and where ARS failed timely to file its complaint after receiving constitutionally adequate notice of the Estate’s rejection of ARS’s claim. View "Accelerated Receivable Solutions v. Hauf" on Justia Law

The State, by and through the State Treasurer of Wyoming and the State Retirement System (collectively, the State), filed this action against Appellees - rating agencies - alleging that the rating agencies were liable for hundreds of millions of dollars in investment losses on mortgage-backed securities during the 2007-2008 financial crisis. The district court granted the rating agencies’ motion to dismiss all claims against them for lack of personal jurisdiction, concluding that the rating agencies did not have sufficient contacts with Wyoming to rise to the level required by the due process clause. The Supreme Court affirmed, holding that the State failed to establish a prima facie case of personal jurisdiction over the rating agencies. View "State v. Moody’s Investors Serv., Inc." on Justia Law

Plaintiffs, individually and on behalf of their children, filed a complaint against Defendants, alleging injury resulting from their rental of a house containing black mold. Defendants made an offer of settlement pursuant to Wyo. R. Civ. P. 68, which Plaintiffs did not accept. Plaintiffs voluntarily dismissed certain claims, and the district court entered judgment as a matter of law for Defendants on the remaining claims. Thereafter, Defendants filed a certificate of costs through which they sought an award of costs pursuant to Wyo. R. Civ. P. 68 and 54(d) and Uniform Rules for District Courts (U.R.D.C.) 501. The district court awarded costs. Plaintiffs appealed, arguing, among other things, that the court erred in awarding costs pursuant to rule 68. The Supreme Court affirmed in part and reversed in part the district court’s award of costs, holding that Rule 68 did not apply to the award of costs in this matter, and that, instead, costs were governed by Rule 54(d). View "Graus v. Ok Invs., Inc." on Justia Law

Plaintiff-tenants filed a complaint against Defendant-landlords alleging injures from carbon monoxide poisoning caused by a gas stove on property Plaintiffs rented from Defendants. Defendants made an offer of settlement to Plaintiffs pursuant to Wyo. R. Civ. P. 68, which Plaintiffs did not accept. After a trial, the jury returned a verdict in favor of Defendants. Thereafter, Defendants filed a motion for costs in the amount of $45,410 pursuant to Wyo. R. Civ. P. 68 and 54(d) and the Uniform Rules for District Courts (U.R.D.C.) 501. The district court awarded Defendants costs in the amount of $1,326 after applying U.R.D.C. 501. The Supreme Court appealed, holding (1) an award of costs pursuant to Rule 68 is governed by Rule 501 and Wyo. Stat. Ann. 1-14-102; and (2) the district court did not abuse its discretion by denying the majority of the costs requested by Defendants pursuant to Rule 54(d) and U.R.D.C. 501. View "Weinstein v. Beach" on Justia Law

Plaintiff filed a complaint against four defendants alleging that they conspired to fabricate a mental incompetency determination in connection with criminal proceedings filed against Plaintiff in Utah. The district court dismissed Plaintiff’s case for failing to properly serve the defendants within ninety days of filing the complaint. The Supreme Court reversed, holding (1) questions existed whether the affidavits of service on three of the defendants established a prima case of valid service, and the fourth defendant waived any objection to lack of proper service; (2) the district court did not err in failing to enter a default against the defendants; and (3) the district judge did not err in not granting Plaintiff’s motion to transfer the case to another district court. Remanded for a hearing to determine the validity of service of process. View "Lundahl v. Gregg" on Justia Law

In 2008, Plaintiff and Defendant were involved in an automobile accident. In 2012, Plaintiff filed a complaint against Defendant alleging that Defendant’s negligent motor vehicle operation caused the collision, resulting in serious injury to Plaintiff. Defendant filed a motion to dismiss, alleging that Plaintiff’s action was barred by the statute of limitations. The district court agreed and granted Defendant’s motion to dismiss with prejudice. Plaintiff appealed, arguing that the district court’s consideration of evidence outside the pleadings converted Defendant’s motion to a summary judgment motion and that genuine issues of material fact precluded dismissal. The Supreme Court affirmed, holding (1) Defendant’s motion was converted to a summary judgment motion, but no issues of material fact precluded entry of the court’s order, and (2) the court properly denied Plaintiff’s assertion of equitable estoppel and correctly ruled that Plaintiff’s action was barred by the statute of limitations. View "Inman v. Boykin" on Justia Law