Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the district court's denial of a motion to set aside default judgment against it after it failed to answer a writ of garnishment, holding that, despite certain procedural infirmities, the district court did not err in denying the motion to set aside default judgment.After Monty Elliott obtained a judgment his efforts to collect led to a writ of garnishment of Sonny Pilcher's earnings from Rack's Gentlemen's Club, a business operated by CC Cowboy's Inc. The district court entered default judgment against CC Cowboys. Pilcher filed a motion to vacate default judgment, which the district court denied. The Supreme Court affirmed, holding that CC Cowboys waived its objection to personal jurisdiction by appearing in the proceeding without making that objection. View "Pilcher v. Elliott" on Justia Law

The Supreme Court affirmed the decision of the district court using a judgment against Alexander Mantle to set off judgments Alexander and Majorie Mantle had against Ray and Gary Garland and failing to recognize the Mantles' right to the proceeds from a settlement of a third-party action against Karl Killmer and Killmer & Associates (collectively, Killmer), holding that the district court did not err.Specifically, the Supreme Court held (1) Ray and Gary were entitled to use the assigned portions of the judgment against Alexander to satisfy the judgments the Mantles had against them for fraudulent transfers; and (2) the district court did not have jurisdiction to the portion of the Killmer settlement funds not deposited with the district court. View "Mantle v. North Star Energy & Construction LLC" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing a corporation's (the Corporation) counterclaims after it was sued by two trusts (the Trusts), holding that the district court erred by dismissing the counterclaims.The Trusts sued the Corporation for payment of loans they made to the Corporation to finance its oil and gas service operations in Australia. The Corporation asserted affirmative defenses and counterclaims. The district court dismissed the counterclaims on the grounds that they unduly complicated the action. The jury ruled that the Trusts had breached the implied covenant of good faith and fair dealing and that the Corporation owed reduced damages to one of the trusts. The Supreme Court reversed, holding (1) the district court erred by dismissing the Corporation's counterclaims because Wyo. R. Civ. P. 13 does not authorize courts to dismiss permissible counterclaims simply because they would unduly complicate the action; and (2) on remand, the court must address a few problems with the jury instructions. View "Gas Sensing Technology Corp. v. New Horizon Ventures Pty Ltd" on Justia Law

In this contract dispute, the Supreme Court affirmed the order of the district court dismissing H&P Advisory Limited's complaint against Randgold Resources, Limited and Barrick Gold Corporation for lack of personal jurisdiction, holding that the undisputed facts and all reasonable inferences in H&P's favor did not support personal jurisdiction over Defendants in Wyoming.Randgold, a Jersey (Channel Islands) corporation, and Barrick, a Canada corporation, were two of the world's largest gold mining companies. H&P, a United Kingdom private limited company, served as a neutral broker between the two companies in a merger deal. Those involved in the merger met in Jackson, Wyoming to participate in a series of negotiations. Randgold and Barrick subsequently announced the merger but did not list H&P as an advisor and offered to pay H&P a "small fee" for its role in the merger. H&P sued Randgold and Barrick in the Ninth Judicial District in and for Teton County, Wyoming alleging breach of contract. The district court dismissed the complaint on personal jurisdiction grounds. The Supreme Court affirmed, holding that the district court correctly concluded that it lacked specific personal jurisdiction over Defendants. View "H&P Advisory Ltd. v. Randgold Resources Ltd." on Justia Law

The Supreme Court affirmed the jury's verdict in favor of Dr. Ronald E. Stevens on Anesthesiology Consultants of Cheyenne, LLC's (ACC) claims for brach of fiduciary duties, breach of the covenant of good faith and fair dealing and breach of contract, holding that there was no error.ACC claimed that Dr. Stevens, its former manager and member, took for himself ACC's business opportunity to provide anesthesiology services to an eye surgery center. When this case was first before the Supreme Court, the Court concluded that the district court erred in granting ACC summary judgment because genuine issues of material fact existed as to ACC's covenant of good faith and fair dealing and breach of fiduciary duty claims. On remand, the jury rendered a verdict in favor of Dr. Stevens on all claims. The Supreme Court affirmed, holding (1) sufficient evidence supported the jury's verdict that Dr. Stevens did not breach his fiduciary duties of loyalty and care or the covenant of good faith and fair dealing; and (2) because the law of the case doctrine did not apply to the district court's summary judgment ruling on ACC's breach of contract claim, the court properly submitted that claim to the jury. View "Anesthesiology Consultants of Cheyenne, LLC v. Stevens" on Justia Law

The Supreme Court affirmed the judgment of the district court finding that Buyer had breached a contract for the sale of a lot in a subdivision and ordering Buyer to specifically perform, holding that the district court did not abuse its discretion when it ordered Buyer to specifically perform.After Buyer entered into a contract with Seller for the sale of the lot Buyer decided he no longer wanted to purchase the lot. Seller filed this lawsuit asserting breach of contract and seeking specific performance. Buyer argued that the contract was unenforceable for failing to comply with the statute of frauds. The district court disagreed and entered judgment in favor of Seller, ordering Buyer to specifically perform the contract. The Supreme Court affirmed, holding (1) while the contract failed to comply with the statute of frauds, it was enforceable under the doctrine of partial performance; and (2) the district court did not abuse its discretion when it ordered Buyer to specifically perform. View "Davis v. Harmony Development, LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Defendant's motion to dismiss Plaintiff's action claiming that Defendant failed to perform under a website development agreement, holding that the district court did not abuse its discretion by dismissing the case for improper venue.The district court determined that Teton County, Wyoming was not the proper venue for Plaintiff's suit because a forum selection clause in the parties' Master Services Agreement (MSA) required any claim or suit arising under the agreement to be litigated in Orange County, California. On appeal, Plaintiff argued that the district court improperly resolved disputed issues of fact in determining that the MSA was a valid contract. The Supreme Court affirmed, holding (1) the district court did not decide any material issues of fact; (2) the MSA governed the parties' relationship; and (3) the district court did not abuse its discretion in granting Defendant's motion to dismiss for improper venue. View "Ecocards v. Tekstir, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of the Jackson Hole Airport Board and dismissing Appellants' petition for declaratory judgment challenging the validity of an asset purchase agreement between the Board and Jackson Hole Aviation, holding that airport boards have the statutory authority to issue revenue bonds to fund the purchase of intangible property, including goodwill.Appellants were two entities interested in providing services at Jackson Hole Airport and individuals dissatisfied with the Airport's current services. Appellants brought this action claiming that the purchase agreement between the Board and Jackson Hole Aviation, the current service provider at the Airport, exceeded the Board's statutory authority because the Board could not acquire intangible assets using revenue bond funding. The district court concluded that the term "other property" in Wyo. Stat. Ann. 10-5-101(a) authorized the use of revenue bonds for purchases of both tangible and intangible property. The Supreme Court affirmed, holding that section 10-5-101(a) authorized purchases of both tangible and intangible property and that the district court correctly determined that goodwill is intangible property included in the term "other property" found in section 10-5-101(a). View "Herrick v. Jackson Hole Airport Board" on Justia Law

In this breach of contract case the Supreme Court affirmed the judgment of the district court denying Appellant's Wyo. R. Civ. P. 60(b) motion, holding that neither documents in a party's possession nor public records in existence at the time of trial are newly discovered evidence if, with due diligence, they could have been discovered prior to trial.In its rule 60(b) motion Appellant argued that two pieces of evidence - one of which it possessed and the other which was a matter of public record at the time of trial - constituted newly discovered evidence. The trial court denied the motion. Appellant appealed, arguing that it was not for a lack of due diligence that it did not discover the documents in its physical possession or data available on a website prior to trial. The Supreme Court disagreed, holding that the district court did not abuse its discretion in finding the evidence was not newly discovered because Appellant failed to exercise due diligence. View "SWC Production, Inc. v. Wold Energy Partners, LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Finley Resources, Inc.'s complaint against EP Energy E&P Company on the grounds that the forum-selection clause contained in the contract between the parties required Finley to file its suit in Texas, holding that the district court did not abuse its discretion in declining to exercise jurisdiction based on the forum-selection clause.On appeal, Finley argued that the district court abused its discretion in dismissing Finley's lawsuit because the declaratory judgment, quiet title, and adverse possession claims did not arise from the parties' contract and, even if the equitable causes of action arose from the contract, the Texas courts lacked subject matter jurisdiction to consider the claims. The Supreme Court disagreed, holding (1) Finley's equitable claims were matters in connection with the contract and were subject to the forum-selection clause; and (2) Finley's claims will necessarily be resolved by the Texas court's determination of its contractual rights. View "Finley Resources, Inc. v. EP Energy E&P Co." on Justia Law