Justia Wyoming Supreme Court Opinion Summaries

Appellant suffered a workplace injury to his back and applied for permanent partial disability. The Workers’ Compensation Division denied benefits. Appellant requested a contested case hearing. During discovery, the Division served interrogatories and requests for production requesting information regarding Appellant’s work history since the time of his injury. Appellant objected to a number of the interrogatories and requests, asserting his Fifth Amendment right against self-incrimination. The hearing examiner compelled Appellant to answer the discovery, but Appellant continued to invoke his Fifth Amendment right against self-incrimination. The hearing examiner dismissed the contested case as a discovery sanction. The district court affirmed. The Supreme Court reversed, holding (1) Appellant was justified in asserting his Fifth Amendment privilege against self-incrimination because he reasonably believed his answers to the discovery requests could be used in a criminal prosecution against him; and (2) the hearing examiner abused his discretion by acting arbitrarily and capriciously in dismissing the case as a discovery sanction without engaging in the proper balancing of Appellant’s and the Division’s conflicting interests. View "Debyah v. State, ex rel., Dep’t of Workforce Servs." on Justia Law

After a jury trial, Defendant was convicted for aiding and abetting aggravated robbery. Defendant appealed, asserting that the district court denied him the right to due process when it refused to instruct the jury on his defense of duress. The Supreme Court reversed and remanded for a new trial, holding that the district court denied Defendant of his right to a fair trial when it ruled that the duress defense instruction would not be given to the jury after Defendant testified and admitted the elements of the crime, as the facts of the case were sufficient to establish a jury question as to Defendant’s duress defense. View "James v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree sexual abuse of a minor and one count of second-degree sexual abuse of a minor. The Supreme Court affirmed, holding (1) the district court did not err in admitting evidence of Appellant’s prior conviction for sexual assault; (2) the district court did not err in excluding evidence of the victim’s prior sexual conduct; (3) the district court did not err in admitting evidence of domestic abuse; and (4) the prosecutor did not commit misconduct in his statements made during closing argument. View "Carroll v. State" on Justia Law

After a jury trial, Defendant was convicted of aiding and abetting aggravated robbery. Defendant appealed, arguing that the district court denied him the right to due process by declining to instruct the jury on his defense of duress. The Supreme Court reversed and remanded for a new trial, holding that Defendant was denied his right to a fair trial when the district court refused to instruct the jury on Defendant’s defense of duress after Defendant testified and admitted the elements of the crime. Given the evidence presented in this case, Defendant was entitled to a jury determination as to whether he had a reasonable opportunity to avoid the crime. View "James v. State" on Justia Law

In this child neglect proceeding, the juvenile court found that it was in the child’s best interest to cease efforts to reunify him with Mother and to change the permanency plan to termination of parental rights and eventually adoption. The Supreme Court affirmed the juvenile court’s order, holding (1) while due process may require an evidentiary hearing when a permanency plan is changed from family reunification to termination of parental rights, Mother failed to establish plain error in the juvenile court’s failure to apply the Wyoming Rules of Evidence during the permanency hearing; and (2) sufficient evidence supported the juvenile court’s finding that to find that it was in the child’s best interests to change the permanency plan to adoption. View "In re GC" on Justia Law

After a jury trial, Defendant was found guilty of three counts of delivery of cocaine. The Supreme Court reversed the conviction and remanded for a new trial, holding (1) the evidence was sufficient to support the conviction; (2) Defendant was not denied his right to confrontation when law enforcement officers testified about results of tests conducted by others; (3) the prosecutor did not commit misconduct; but (4) Defendant’s trial counsel rendered ineffective assistance by failing to object to improper testimony and argument, by failing to demand notice of Wyo. R. Crim. P. 404(b) evidence and enter an objection to the testimony, and by failing to request that audio tapes of controlled buys be played in their entirety, and Defendant was prejudiced by counsel’s deficient performance. View "Fennell v. State" on Justia Law

After a jury trial, Appellant was convicted of child abuse and third-degree sexual assault of a minor under Wyo. Stat. Ann. 6-2-503(b)(i) and Wyo. Stat. Ann. 6-2-316(a)(iv). The Supreme Court affirmed, holding (1) Appellant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48 and under the Sixth Amendment to the United States Constitution; (2) the State presented sufficient evidence to sustain Appellant’s conviction of sexual abuse of a minor in the third degree; and (3) Appellant was not deprived of the effective assistance of trial counsel. View "Rhodes v. State" on Justia Law

Plaintiff filed a complaint against Defendant, her former employer, alleging harassment, emotional stress, personal injury, loss of income, and age discrimination. The district court dismissed the complaint for lack of subject matter jurisdiction and for failure to state a claim. The Supreme Court affirmed, holding (1) the district court correctly dismissed Plaintiff’s discrimination and harassment claims where she not only failed to allege timely satisfaction of the statutory jurisdictional conditions precedent but failed to timely comply with the jurisdictional conditions precedent; and (2) the district court properly dismissed Plaintiff’s state law tort claims. View "Apodaca v. Safeway, Inc." on Justia Law

The three petitioners in this case (collectively, “Petitioners”) were held in the Fremont County Detention Center on unrelated criminal charges. None of the Petitioners were able to post the cash-only bail imposed by the lower courts as a condition of their pretrial release. As a result, each Petitioner remained in jail pending trial. Each Petitioner filed a petition to the Supreme Court for habeas corpus relief seeking immediate release from the detention center and requesting a determination that cash-only bail is impermissible under the Wyoming Constitution and Rules of Criminal Procedure. The Supreme Court consolidated the petitions for review and affirmed the lower courts’ use of cash-only bail, holding that cash-only bail does not violate Wyo. Const. art. I, 14 or Wyo. R. Crim. P. 46.1. View "Saunders v. Hornecker" on Justia Law

After a jury trial, Defendant was found guilty of three counts of first degree sexual abuse of a minor and three counts of second degree sexual abuse of a minor for acts involving two victims. Defendant was also found guilty of two counts of aggravated assault and two counts of first degree sexual assault for acts involving an adult victim. The Supreme Court affirmed the convictions, holding (1) the district court erred when it allowed the State to introduce un-noticed character evidence, but the error was harmless; (2) the State's amendment to the information did not prejudice Defendant’s substantial rights; and (3) Defendant was not denied his right to a fair trial due to prosecutorial misconduct. View "Lindstrom v. State" on Justia Law