Justia Wyoming Supreme Court Opinion Summaries

Several property owners and ranching entities challenged amendments adopted in 2023 by the Albany County Board of County Commissioners to the Aquifer Protection Overlay Zone (APOZ) regulations. The Casper Aquifer, which supplies drinking water to many residents of Albany County and the City of Laramie, had been the subject of prior regulatory efforts. The 2023 amendments included a 35-acre minimum lot size requirement and revised procedures for changing the APOZ boundaries. Appellants argued that the Board exceeded its authority, violated equal protection guarantees, and acted arbitrarily and capriciously in enacting the amendments.Previously, in Bienz v. Board of County Commissioners, County of Albany, 2024 WY 102 (Bienz I), the Wyoming Supreme Court reviewed whether amendments to the APOZ regulations were subject to direct judicial review under the Wyoming Administrative Procedure Act (WAPA). The district court had concluded it lacked jurisdiction, finding the Board's actions legislative and not reviewable under the WAPA. The Supreme Court reversed, holding that legislative agency actions are reviewable, and remanded the case for the district court to consider the merits. While litigation was pending, the Board further amended the APOZ regulations, requiring the district court to identify which amendments remained at issue. The district court ultimately upheld the Board’s authority and the amendments.On appeal, the Supreme Court of Wyoming addressed whether the Board exceeded its authority, whether the amendment procedures violated equal protection, and whether the arbitrary and capricious standard applied to agency legislative action. The Court held the Board acted within its statutory authority in protecting the Casper Aquifer, the distinct procedures for overlay zone amendments did not violate equal protection guarantees, and agency legislative actions are subject to the arbitrary and capricious standard. It concluded the 2023 APOZ amendments, including the 35-acre minimum lot size, were not arbitrary, capricious, or contrary to law, and affirmed the district court’s decision. View "Warren Livestock, LLC v. Board of County Commissione" on Justia Law

A minor child, S.M., through a conservator, alleged abuse at a residential facility operated by Meadowlark Academy, asserting several tort claims against Meadowlark and two individuals. Meadowlark responded by filing counterclaims, including breach of contract, based on an alleged pre-litigation settlement agreement. S.M. (at that time, not yet represented by a conservator) failed to timely answer the counterclaims. There was a substantial delay before a conservator, Mr. Moran, was formally appointed and filed an amended complaint. Meadowlark then sought and obtained entry of default against Moran for failing to answer the counterclaims. Moran eventually answered, but only after default had been entered and a motion for default judgment was pending.The District Court of Laramie County denied Meadowlark’s initial motion to dismiss, finding that S.M. had standing despite procedural irregularities regarding the appointment of a conservator, and that there was no enforceable settlement agreement. After Meadowlark asserted counterclaims, the court entered default when those claims were not answered. Moran filed a late answer and opposed default judgment but did not specifically move to set aside the default under the relevant procedural rules or provide supporting legal authority. The district court granted default judgment to Meadowlark and, by implication, denied Moran’s oral motion to set aside the default.On appeal, the Supreme Court of the State of Wyoming affirmed the district court’s order. The Supreme Court held that Moran failed to establish good cause to set aside the entry of default under Wyoming Rules of Civil Procedure 55(c) and 60(b), as he did not articulate a valid legal justification or provide supporting argument and authority. The court also held that Moran’s due process rights were not violated, as he had notice and an opportunity to be heard through his counsel. The judgment was affirmed. View "Moran v. Meadowlark Academy Inc." on Justia Law

The Wyoming legislature enacted the Steamboat Legacy Scholarship Act in 2025, creating an education savings account (ESA) program. This program allows parents of eligible Wyoming school-aged children to apply for up to $7,000 annually to fund education expenses outside the public school system. The ESAs are funded from a state general fund appropriation, not from local or school district taxes. Plaintiffs, including the Wyoming Education Association (WEA) and several individual parents, challenged the Act’s constitutionality, claiming it violated provisions of the Wyoming Constitution related to public education and state appropriations. The plaintiffs argued that the Act would harm their children, particularly those with disabilities, because private schools receiving ESA funds could deny admission or fail to provide needed services.The District Court of Laramie County granted a preliminary injunction, preventing implementation and funding of the ESA program while the lawsuit proceeded. The district court found that the plaintiffs were likely to succeed on the merits of their constitutional claims and that they would suffer irreparable injury if funds were distributed under the Act. The court reasoned that the Act likely violated constitutional limitations on appropriations for educational purposes to entities not under state control, and infringed upon the fundamental right to education by diverting funds from the public system.On appeal, the Supreme Court of Wyoming reviewed the district court’s decision for abuse of discretion. The Supreme Court held that the plaintiffs had not made a clear showing of possible irreparable, personal injury required for preliminary injunctive relief, as they did not intend to participate in the ESA program and their alleged harms were speculative. The court also questioned the district court’s legal analysis but did not decide the case on the merits. The Supreme Court of Wyoming reversed the preliminary injunction and remanded the case for further proceedings. View "Degenfelder v. Wyoming Education Association" on Justia Law

The defendant was involved in a violent incident with his girlfriend and their young daughter, during which he physically assaulted the girlfriend multiple times, including striking her with his fists and a handgun, strangling her to unconsciousness, and kicking her to the extent of causing severe injuries. Their daughter also sustained injuries. The defendant was charged with several felonies, including aggravated assault, battery, strangulation of a household member, and child abuse. He was also facing charges in other unrelated cases. The parties reached a global plea agreement covering all the charges, under which the defendant pled guilty to certain offenses, and the State agreed to dismiss others in exchange for restitution and the right for both sides to argue sentence.In the District Court of Goshen County, the defendant was sentenced to consecutive prison terms for the charges to which he pled guilty. At sentencing, the victim presented both oral and written impact statements, some of which referred to uncharged conduct by the defendant, including additional incidents of abuse and property theft or destruction. The defendant did not object to the use of these statements at sentencing.On appeal to the Supreme Court of the State of Wyoming, the defendant argued that the district court erred by considering the victim impact statements referencing uncharged crimes. The Wyoming Supreme Court applied the plain error standard, since no objection was raised below. The court held the defendant failed to show that the district court relied on inaccurate or unreliable information in imposing sentence; the record reflected the court’s decision relied on the violent nature of the charged offenses and the defendant’s criminal history, not on the contested statements. The court found no plain error or violation of due process, and affirmed the district court’s sentencing decision. View "Atkinson v. The State of Wyoming" on Justia Law

The appellant was convicted of delivery of methamphetamine, second or subsequent offense, and received a suspended sentence with three years of supervised probation. Conditions of probation included obeying Department of Corrections rules and completing any treatment required by his probation officer. After seven months, the State filed a petition to revoke probation, alleging that the appellant left required inpatient treatment at Southwest Counseling Service without completing it. The probation officer’s affidavit detailed that he left treatment against staff advice, had missed office visits, continued to use methamphetamine, and had fled from the probation office, resulting in new criminal charges.The District Court of Carbon County held a probation revocation hearing. Although the appellant initially admitted violating probation, he later claimed his attendance at inpatient treatment was voluntary. The court proceeded to an evidentiary hearing, where the probation officer testified about the appellant’s ongoing drug use, failure to attend required evaluations, and his departure from treatment. The court found by a preponderance of the evidence that he violated probation by not completing required treatment, revoked his probation, and imposed the underlying six to ten-year prison sentence, citing willful violations and unsuitability for continued probation. The appellant appealed, arguing that his due process rights were violated when the State relied on other uncharged probation violations during the dispositional phase.The Supreme Court of Wyoming reviewed the case under the plain error standard because the due process argument was not raised below. The court held there was no due process violation, explaining that written notice is required only for the specific alleged probation violation that forms the basis for revocation, not for other conduct considered during the dispositional phase. The court affirmed the district court’s order revoking probation and imposing the prison sentence, finding no clear or unequivocal rule of law was violated. View "Bustos v. The State of Wyoming" on Justia Law

A 15-year-old boy shot and killed his former girlfriend, a 17-year-old, after sending her harassing and threatening messages. The confrontation occurred at a park following an exchange with the victim’s cousin, which escalated into a plan to fight. The defendant brought his mother’s handgun to the scene and, during the confrontation, shot the victim in the face as she approached him. He was apprehended shortly after the shooting and confessed to law enforcement.The State originally charged the defendant with first-degree murder and misdemeanor stalking. Pursuant to a plea agreement, he pled guilty to second-degree murder and stalking. At sentencing, the prosecutor and defense agreed that an individualized hearing was appropriate, given the defendant’s juvenile status. The prosecution recommended a sentence of 44 to 75 years for the murder conviction, referencing Wyoming’s Bear Cloud line of cases and statutory limits for juvenile offenders. The defense argued that, under Wyoming law and constitutional principles, the maximum allowable sentence for a juvenile convicted of homicide should be 22.5 years to life, or at most a minimum term not exceeding 43 years. The District Court of Natrona County sentenced the defendant to 42 to 75 years for second-degree murder and time served for stalking.On appeal, the Supreme Court of the State of Wyoming reviewed whether (1) Wyoming’s juvenile parole eligibility statute applied, (2) the sentence exceeded statutory limits, and (3) the sentence violated the Wyoming Constitution’s prohibition on cruel or unusual punishment. The Court held that the parole eligibility statute applied only to life sentences, not to terms of years. The sentence fell within statutory limits for second-degree murder. Finally, the Court found the sentence was not “unusual” under the state constitution because there was no consensus among legislatures or courts that such a sentence for a juvenile was unlawful. The Supreme Court affirmed the district court’s judgment. View "Castaner v. The State of Wyoming" on Justia Law

The case involved allegations that a man sexually abused his stepdaughter, JB, when she was a child and later sexually assaulted his biological daughter, FO, when she was a teenager. After JB disclosed the abuse to her probation officer, both she and FO were interviewed by police and provided accounts implicating the defendant in two separate incidents of sexual intrusion. The State charged the defendant with two counts of first-degree sexual abuse of a minor.During trial proceedings in the District Court of Campbell County, the court granted the defendant’s motion to sequester witnesses. However, it was discovered that JB and FO overheard brief portions of a livestream of the trial while waiting to testify, in violation of the sequestration order. The district court questioned the witnesses outside the jury's presence, found no intentional or prejudicial violation, and allowed limited cross-examination on what they overheard, but did not permit questioning about their violation of a court order. The defendant also moved for mistrials based on allegedly improper testimony referencing uncharged conduct under Wyoming Rule of Evidence 404(b), but the court either struck the testimony and instructed the jury to disregard it or found the testimony did not reference uncharged acts, and denied the motions.On appeal, the Supreme Court of Wyoming reviewed whether the district court abused its discretion in limiting the scope of cross-examination and denying mistrials, and whether the defendant’s Confrontation Clause rights were violated. The court held that the district court acted within its discretion, as the violations of the sequestration order were minimal and non-prejudicial, and the limitations on cross-examination did not infringe on the defendant’s confrontation rights. The court also found no abuse of discretion in denying the motions for mistrial and found no cumulative error. The Supreme Court of Wyoming affirmed the convictions. View "O'Dell v. The State of Wyoming" on Justia Law

In 2023, Wyoming enacted two laws restricting abortion: the Life is a Human Right Act, which broadly banned abortion procedures with limited exceptions, and a separate statute prohibiting the prescription or use of drugs to induce abortions, also with exceptions. These laws imposed criminal and civil penalties on violators, excluding the pregnant person. After the laws took effect, several plaintiffs—including medical professionals, non-profit organizations, and an individual woman—challenged the statutes in District Court of Teton County, arguing they violated Article 1, Section 38 of the Wyoming Constitution, which guarantees each competent adult the right to make their own health care decisions.The district court granted summary judgment in favor of the plaintiffs, finding that the challenged laws unreasonably and unnecessarily infringed on the constitutional right to make health care decisions, and issued a permanent injunction preventing enforcement of the abortion restrictions. The State of Wyoming appealed directly to the Wyoming Supreme Court.The Wyoming Supreme Court, exercising de novo review, held that the decision to terminate or continue a pregnancy is a health care decision protected by Article 1, Section 38. The Court determined that this provision confers a fundamental right, and that statutes restricting it must satisfy strict scrutiny: the State must show such laws are narrowly tailored to achieve a compelling governmental interest and use the least restrictive means. The majority found that the State failed to present sufficient evidence that the abortion restrictions and their exceptions were the least restrictive means of protecting prenatal life. Accordingly, the Wyoming Supreme Court affirmed the district court’s ruling, holding the 2023 abortion laws unconstitutional under the Wyoming Constitution. View "State of Wyoming v. Johnson" on Justia Law

A married couple with two young children went through divorce proceedings after the mother filed for divorce. During the marriage, the mother was the primary caregiver, staying home with the children, while the father worked long hours as a mechanic and business owner. Both parties presented evidence at trial regarding their respective parenting abilities, disciplinary approaches, and their differing views on matters such as medical care and education. Testimony addressed concerns about each parent’s past drinking, interactions with the children, willingness to facilitate contact with the other parent, and incidents involving the children’s care.The District Court of Washakie County conducted a bench trial and, after evaluating the statutory best interest factors, awarded joint legal custody of the children to both parents. The court designated the mother as the primary residential caregiver and final decision-maker for major matters, granting the father regular parenting time, including certain weekends, evenings, holidays, and summer periods. The father appealed the custody determination, arguing that the court violated his constitutional rights by not granting equal parenting time and claiming the court abused its discretion in its allocation of parenting time.The Supreme Court of Wyoming reviewed the appeal. It held that, in custody disputes between two fit parents, the constitutional principles cited in cases like Troxel v. Granville do not require courts to allocate equal parenting time. Instead, the court reaffirmed that Wyoming law requires custody to be determined according to the best interests of the children, without any presumption in favor of equal or shared custody. The Supreme Court found that the district court had thoroughly considered the statutory factors, acted within its discretion, and did not violate the father’s fundamental rights. The Supreme Court of Wyoming affirmed the district court’s custody order. View "Smith v. Smith" on Justia Law

The plaintiffs, all residents, property owners, and taxpayers in Johnson County, Wyoming, brought a declaratory action against the county’s Board of Commissioners and the Wyoming Department of Audit (including its Director). Their complaint alleged that the Board mismanaged county finances and violated state fiscal statutes, and that the Department failed to enforce compliance. The plaintiffs claimed that these actions caused them tangible harm as taxpayers through increased taxes and fees. Their suit included ten counts, all seeking declarations of statutory or constitutional violations and requesting judicial oversight, including a forensic audit.The District Court of Johnson County reviewed the case after the Board and the Department moved to dismiss, arguing that the plaintiffs lacked standing to sue. The district court agreed, finding that the plaintiffs had not demonstrated a sufficient personal or particularized injury, and dismissed the complaint for lack of standing. The plaintiffs appealed to the Wyoming Supreme Court.The Supreme Court of Wyoming affirmed the district court’s dismissal. The court held that the plaintiffs failed to establish prudential standing under Wyoming’s Brimmer test, which requires a tangible personal stake in the outcome, not just a generalized grievance. The court also declined to recognize taxpayer standing, since the plaintiffs’ claims of increased tax burdens were speculative and unsupported by specific factual allegations. Even though the plaintiffs argued the case was of great public importance, the court held that public interest alone is insufficient to relax standing requirements without a concrete, particularized harm. As a result, the Supreme Court affirmed the dismissal of the action for lack of standing. View "Williams v. Board of County Commissioners of Johnson County" on Justia Law