Justia Wyoming Supreme Court Opinion Summaries

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