Justia Wyoming Supreme Court Opinion Summaries

Clifford Bain was seriously injured when a bus owned and operated by the City of Cheyenne collided with him while he was riding his motorcycle. Bain filed a complaint against the bus driver and the City under the Wyoming Governmental Claims Act (WGCA). The bus driver and the City admitted liability but claimed immunity from any liability exceeding $250,000 under the WGCA. Bain then filed a motion for partial summary judgment, arguing that the limitation in § 1-39-118(a)(i) of the WGCA was unconstitutional under Article 10, § 4(a) of the Wyoming Constitution. The district court denied Bain’s motion, declaring the statute constitutional. Bain subsequently filed a petition for writ of review with the Wyoming Supreme Court.The district court denied Bain’s motion for partial summary judgment, holding that § 1-39-118(a)(i) of the WGCA is not a limitation on damages but rather a limitation on the waiver of immunity. Bain then filed a petition for writ of review, which the Wyoming Supreme Court granted.The Wyoming Supreme Court reviewed the case de novo and affirmed the district court’s decision. The Court held that § 1-39-118(a)(i) is a limitation on the waiver of immunity under the WGCA and not a limitation on damages, thus it does not violate Article 10, § 4(a) of the Wyoming Constitution. The Court emphasized that the statute limits the legal responsibility or obligation of governmental entities and is consistent with the legislative intent to balance the equities between injured persons and taxpayers. The Court concluded that Bain did not meet his burden of proving the statute unconstitutional. View "Bain v. City of Cheyenne" on Justia Law

Sandra Malone (Grandmother) filed a lawsuit against Salvador Galvan (Father) seeking visitation rights with ALG, the child of her deceased daughter. Father and Mother had a child, ALG, in July 2022. They regularly attended family dinners with Mother’s family, including Grandmother. After Mother’s death in an ATV accident caused by Father, Grandmother accused Father of killing Mother and supported his criminal prosecution. Father, concerned about Grandmother’s negative impact on ALG, stopped attending family dinners and discontinued visits between ALG and Grandmother, although he maintained relationships with other family members.The District Court of Albany County held a trial and granted Grandmother visitation rights. The court found that Grandmother had a significant preexisting relationship with ALG and concluded that Father’s decision to discontinue visits with Grandmother was harmful to ALG. The court awarded Grandmother visitation despite acknowledging concerns about her animosity towards Father and the potential negative impact on ALG.The Supreme Court of Wyoming reviewed the case. The court held that the district court erred in its findings. It emphasized that Grandmother needed to prove by clear and convincing evidence that Father’s decision to restrict visitation was harmful to ALG. The court found that Grandmother did not present any evidence of harm, while Father’s expert testified that visitation with Grandmother could harm ALG due to the hostile relationship between Father and Grandmother. The Supreme Court concluded that the district court violated Father’s constitutional rights as a parent by granting Grandmother visitation without sufficient evidence of harm to ALG.The Supreme Court of Wyoming reversed the district court’s decision, holding that the lower court clearly erred in finding that Grandmother established harm by clear and convincing evidence. View "Galvan v. Malone" on Justia Law

David Herrera, Jr. pled guilty to aggravated robbery with a deadly weapon and was sentenced to five to eight years in prison by the district court, which recommended his placement in the Youthful Offender Transition Program (YOTP). Herrera filed a motion for sentence reduction upon nearing completion of the YOTP, asserting that the district court had promised to reduce his sentence if he successfully completed the program.The district court denied Herrera’s motion for sentence reduction without holding a hearing or providing an explanation. Herrera appealed, arguing that the district court abused its discretion and violated his constitutional rights by not honoring the promise made during sentencing.The Wyoming Supreme Court reviewed the case and found that the district court’s oral pronouncement at sentencing, which stated Herrera “will get a sentence reduction” if he completed the YOTP, constituted an express commitment. The court held that the district court abused its discretion by denying the motion for sentence reduction without justification, given the prior commitment. The Supreme Court reversed the district court’s decision and remanded the case for further sentencing proceedings consistent with its opinion. View "Herrera v. The State of Wyoming" on Justia Law

William Patterson was convicted of sexually abusing his girlfriend’s four-year-old niece. The incident occurred on September 15, 2019, when Patterson was watching the child and her twin sister. The children later reported the abuse to their mother, who contacted the police. The children were interviewed, and one disclosed the abuse. However, the district attorney initially decided not to charge Patterson. Three years later, the children provided more details, leading to charges against Patterson. He was convicted by a jury of second and third-degree sexual abuse of a minor.The District Court of Natrona County sentenced Patterson to 14-20 years in prison for second-degree sexual abuse of a minor, noting that the same act formed the basis for both convictions. Patterson appealed, arguing that the prosecutor improperly commented on his right to remain silent during the trial. The district court had denied Patterson’s motion for a mistrial, concluding that the prosecutor’s statement was not an improper comment on his right to remain silent and that any potential prejudice was mitigated by the court’s curative actions.The Supreme Court of Wyoming reviewed the case and determined that the prosecutor’s statement during opening arguments, which mentioned Patterson’s refusal to speak with law enforcement, was an impermissible comment on his constitutional right to remain silent. The court reaffirmed that such comments are prejudicial per se under the Wyoming Constitution and require reversal of the conviction. The court overruled previous case law that allowed for a distinction between a “comment” and a “reference” to silence, clarifying that any improper comment on the right to silence is prejudicial per se. Consequently, the Supreme Court of Wyoming reversed Patterson’s conviction and remanded the case for a new trial. View "Patterson v. State" on Justia Law

Joseph W. Russell entered a conditional guilty plea to possession of methamphetamine, reserving his right to appeal the constitutionality of a warrantless search conducted as he entered the Uinta County Courthouse. The search, performed by Deputy Dan Jensen, involved a magnetometer alerting to metal in Russell's waist area, leading to a pat-down and the discovery of a snus can containing methamphetamine. Russell was charged with felony possession of a controlled substance.The district court denied Russell's motion to suppress the evidence, finding the search reasonable under the Fourth Amendment. Russell entered a conditional guilty plea, allowing him to appeal the suppression order. He was sentenced to one to three years of imprisonment, suspended in favor of two years of supervised probation. Russell timely appealed the denial of his motion to suppress.The Wyoming Supreme Court reviewed the case, focusing on whether the search violated the Fourth Amendment. The court applied a three-part test to determine the reasonableness of the search: the nature and immediacy of the governmental concern, the efficacy of the search in addressing that concern, and the nature of the privacy interest upon which the search intrudes. The court found that courthouse security is a compelling governmental interest, the use of a magnetometer and follow-up searches are effective in addressing this concern, and the privacy interest in the snus can was minimal given the context of courthouse security.The court concluded that the search was reasonable and affirmed the district court's denial of Russell's motion to suppress. The holding emphasized that the search was justified under the special needs exception to the Fourth Amendment, balancing the government's interest in courthouse security against the minimal intrusion on Russell's privacy. View "Russell v. State" on Justia Law

Amy Romero was arrested for driving while under the influence of alcohol (DWUI) after being found stuck in a snowbank. Officer George Phillips of the Rawlins Police Department noticed the vehicle and, upon investigation, detected a strong odor of alcohol from Ms. Romero. During the interaction, Ms. Romero admitted to driving the vehicle and exhibited signs of intoxication. Officer Phillips placed her in the back of his patrol car to deescalate a potentially violent situation with her husband, Joseph Romero, who was also present and behaving aggressively.The Office of Administrative Hearings (OAH) upheld the suspension of Ms. Romero’s driver’s license, concluding that Officer Phillips had reasonable suspicion to detain her for a DWUI investigation. The OAH found that the officer’s actions, including placing Ms. Romero in the patrol car and transporting her to a dry environment for field sobriety tests, were justified based on the totality of the circumstances, including the strong odor of alcohol, her admission of driving, and the need to manage her husband’s aggressive behavior.The Wyoming Supreme Court reviewed the case and affirmed the OAH’s decision. The Court held that Officer Phillips’ detention of Ms. Romero in the back of the patrol car did not constitute an unlawful arrest but was a reasonable investigative detention supported by substantial evidence. The Court found that the officer’s actions were necessary to ensure safety and were within the scope of a lawful investigative detention. The Court concluded that the OAH’s findings were supported by substantial evidence and that the detention was in accordance with constitutional protections. The decision to uphold the suspension of Ms. Romero’s driver’s license was affirmed. View "Romero v. State of Wyoming Ex Rel., Wyoming Department of Transportation" on Justia Law

Solomon Bolen was convicted of multiple offenses, including attempted second-degree murder and aggravated assault and battery. Bolen appealed, arguing that the district court violated his due process rights by not instructing the jury on his plea of not guilty by reason of mental illness or deficiency (NGMI). He also claimed that his attorneys were ineffective for not seeking those instructions. Additionally, Bolen contended that his convictions for attempted second-degree murder and aggravated assault and battery violated his right against double jeopardy.The district court had found Bolen mentally fit to proceed with the trial. Despite Bolen's NGMI plea, the court-designated examiner, Dr. Wilkinson, opined that Bolen did not meet the statutory criteria for an NGMI defense. She noted that Bolen's altered state of mind and psychosis at the time of the crimes were caused by self-induced intoxication, which is specifically excluded from the statutory definition of mental illness or deficiency. Bolen's attorneys did not pursue the NGMI defense and focused instead on the self-induced intoxication defense.The Supreme Court of Wyoming affirmed the lower court's decision. The court found that Bolen did not present competent evidence to support an NGMI defense, and thus was not entitled to have the jury instructed on the defense. The court also found that Bolen's attorneys were not ineffective for not pursuing the NGMI defense, as the instructions would not have been proper even if they had renewed their request for them. Lastly, the court held that Bolen's convictions for attempted second-degree murder and aggravated assault and battery did not violate his right against double jeopardy, as the crimes contained separate elements. View "Bolen v. State" on Justia Law

In the case before the Supreme Court of Wyoming, State Representatives Rachel Rodriguez-Williams and Chip Neiman, and Right to Life of Wyoming, Inc., attempted to intervene in a lawsuit challenging the constitutionality of two Wyoming laws restricting abortion. The district court denied their motion to intervene, and they appealed that decision. The Supreme Court of Wyoming affirmed the lower court's decision, holding that the proposed intervenors did not meet the requirements for intervention as of right. The court found that the proposed intervenors did not demonstrate a significant protectable interest in the lawsuit. The court also found that the State of Wyoming, represented by the Attorney General, adequately represented the proposed intervenors' interests in defending the challenged laws. Additionally, the court found that allowing the proposed intervenors to participate in the lawsuit would unduly delay and prejudice the case's adjudication. Therefore, the court also denied the proposed intervenors' motion for permissive intervention. View "Rodriguez-Williams v. Johnson" on Justia Law

In this case, the City of Laramie, Wyoming, sued the University of Wyoming and its Board of Trustees, challenging the drilling and operation of certain water wells. The city argued that the university was in violation of a 1965 deed covenant prohibiting the drilling of one of the wells and was also in violation of a city ordinance. The city also claimed that legislation exempting the university from this city ordinance was unconstitutional. The district court dismissed some of the city's claims and granted summary judgment in favor of the university on the remaining claims. The Supreme Court of Wyoming affirmed the lower court's decision. The court held that the university was protected by sovereign immunity from the city's attempts to enforce the deed covenant. It also held that the state law exempting the university from the city ordinance was constitutional. The court further noted that the law precluded the city from enforcing its ordinance against the university. View "City of Laramie, Wyoming v. University of Wyoming" on Justia Law

In Wyoming, Remi Larsen was facing a misdemeanor charge for possession of a controlled substance. Larsen moved to suppress evidence obtained during a warrantless search of her apartment. The trial court granted Larsen's motion, ruling that she did not voluntarily consent to the search. The State appealed this decision, resulting in the district court reversing the trial court's order. On further appeal, the Supreme Court of Wyoming held that the district court abused its discretion when it initially granted the State's petition for an interlocutory writ of review. The Supreme Court explained that the district court should only grant such a review in "rare and unusual" cases that present questions of first impression, constitutional magnitude, and great public import. The court found that Larsen's case did not meet these criteria. The court's order was reversed, and the lower court was directed to reinstate the original suppression order. View "Larsen v. State" on Justia Law