Justia Wyoming Supreme Court Opinion Summaries

Basecamp Teton WY SPV LLC (Basecamp) received a permit from the Wyoming Department of Environmental Quality (DEQ) to construct and operate a septic system for its glamping operation in Teton County, Wyoming. Protect Our Water Jackson Hole (POWJH), a nonprofit organization, sought a declaratory judgment claiming that DEQ lacked the authority to issue the permit due to a delegation agreement transferring permitting authority to Teton County. POWJH also requested an injunction to stay the permit during the litigation. The district court dismissed the complaint, citing several arguments from DEQ and Basecamp, including POWJH's lack of standing.The district court found that POWJH did not establish that a favorable decision would remedy any injury it suffered, as it was unclear whether Teton County would have denied the permit if Basecamp had applied there instead of to DEQ. The court also noted that POWJH was not a party to the delegation agreement and thus could not enforce it. POWJH's motion for reconsideration or to amend the complaint was denied, and the district court's dismissal was based on POWJH's lack of standing among other reasons.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision, focusing on POWJH's lack of standing. The court held that POWJH did not demonstrate a tangible interest that was harmed by DEQ's issuance of the permit. POWJH's allegations about its expenditures on water quality initiatives were deemed too vague and conclusory to establish a specific injury. Additionally, POWJH failed to show how the septic permit would directly harm its efforts or distinguish its interests from those of the general public. As a result, the court concluded that POWJH lacked standing to pursue the declaratory judgment action. View "Protect Our Water Jackson Hole v. Wyoming Department of Environmental Quality" on Justia Law

In 2023, Basin Authority, a Wyoming Child Support Agency, notified Rodolfo P. Munoz that he was in arrears on his child support obligation and began garnishing his social security. Mr. Munoz filed a complaint against the State of Wyoming, the Wyoming Department of Family Services (DFS), and some of its employees, as well as Basin Authority and several of its employees. He alleged breach of contract and violations of due process under 42 U.S.C. § 1983. The district court dismissed Mr. Munoz’s complaint after a hearing.The district court of Big Horn County granted the motions to dismiss filed by the State Defendants and the Basin Authority Defendants. The court found that Mr. Munoz had not made allegations against the State Defendants and that they were not subject to suit under § 1983 because they are not “persons” within the meaning of the statute. The court also found that a breach of contract claim is not actionable under § 1983 and that the alleged agreement was void and unenforceable. Mr. Munoz’s objection and response to the State Defendants’ proposed order on the motion to dismiss and his motion for reconsideration were denied.The Supreme Court of Wyoming reviewed the case and summarily affirmed the district court’s decision. The court noted that Mr. Munoz failed to comply with the Wyoming Rules of Appellate Procedure and did not present cogent arguments supported by pertinent authority. The court emphasized that even pro se litigants must adhere to procedural rules and present coherent arguments. The court concluded that summary affirmance was appropriate due to the deficiencies in Mr. Munoz’s brief and his failure to present relevant legal arguments. View "Munoz v. State of Wyoming" on Justia Law

The Wyoming Board of Land Commissioners (Board) manages state trust lands for the benefit of public schools. In Teton County, the Board issued temporary use permits to Basecamp Hospitality, LLC and Wilson Investments, LLC for commercial activities on state trust lands. Teton County challenged these permits, arguing they should be subject to local land use regulations. The district court dismissed Teton County's challenge, stating the county lacked standing for judicial review. Subsequently, Teton County issued abatement notices to the permit holders, which led the Board to seek declaratory and injunctive relief, claiming sovereign immunity from local regulations.The Teton County Board of County Commissioners (Teton County) filed a petition for review, which was dismissed by the Ninth Judicial District Court. The Board then filed for declaratory judgment and injunctive relief in the First Judicial District, Laramie County, Wyoming. The district court issued a temporary restraining order and preliminary injunction against Teton County's enforcement actions. Citizens for Responsible Use of State Lands (CRUSL), formed by local property owners, sought to intervene, claiming their interests were directly impacted by the use of the state trust lands.The Wyoming Supreme Court reviewed the case. CRUSL argued it had a significant protectable interest due to the proximity of its members' properties to the state trust lands. However, the court found CRUSL's interests were contingent on the outcome of the sovereign immunity issue and thus not significant protectable interests. Additionally, the court held that Teton County adequately represented CRUSL's interests, as both sought to enforce local regulations on state trust lands. Consequently, the court affirmed the district court's denial of CRUSL's motion to intervene as a matter of right under Wyoming Rule of Civil Procedure 24(a)(2). View "Citizens for Responsible Use of State Lands v. State" on Justia Law

The State of Wyoming owns a 3.37-acre parcel in Uinta County, leased to Pilot Corporation for operating a truck stop. The property, held for the benefit of the Wyoming State Hospital, generates revenue for the hospital through the lease. In 2022, the Uinta County Assessor assessed the property for taxation, which the State contested, claiming the property was used primarily for a governmental purpose and thus exempt from taxation.The County Board of Equalization initially ruled in favor of the State, stating the property was used for a governmental purpose because the Board of Land Commissioners had a fiduciary duty to generate revenue for the hospital. However, the State Board of Equalization reversed this decision, holding that the Department of Revenue’s rules, which state that governmental property used by a lessee for non-governmental purposes is not tax-exempt, were binding. The district court affirmed the State Board’s decision, agreeing that the lessee’s use of the property for a truck stop did not constitute a governmental purpose.The Wyoming Supreme Court reviewed the case and affirmed the district court’s ruling. The Court held that the property was not exempt from taxation because it was used by the lessee, Pilot Corporation, for a non-governmental purpose. The Court emphasized that the end use of the property by the lessee determines its tax status, not the purpose of the lease. Additionally, the Court found that the legislature had not provided an exemption for such properties, as required by the Wyoming Constitution. Therefore, the property was subject to taxation. View "State of Wyoming v. Uinta County Assessor" on Justia Law

A group of property owners and entities challenged the Albany County Board of County Commissioners' amendments to zoning regulations known as the Aquifer Protection Overlay Zone (APOZ). The amendments aimed to protect the Casper Aquifer, which supplies drinking water to many residents in Albany County, including those in the City of Laramie. The property owners argued that the Board's adoption of the amendments was arbitrary, capricious, and exceeded its authority.The District Court of Albany County dismissed the petitions for review, concluding that it lacked jurisdiction because the amendments were legislative acts and not reviewable under the Wyoming Administrative Procedure Act (WAPA). The property owners and entities appealed, arguing that the Board's actions were reviewable and that the Board lacked the authority to adopt the amendments.The Wyoming Supreme Court reviewed the case and clarified that there is no common law or general statutory exception to judicial review of agency legislative actions. The court held that the characterization of the Board’s action as legislative or adjudicatory dictates the scope and nature of the review. The court concluded that the district court has jurisdiction to review the APOZ amendments and remanded the case to the district court to conduct an analysis in conformance with the opinion. The court emphasized that judicial review of agency legislative actions is limited by the separation of powers doctrine and should focus on whether the actions were contrary to constitutional rights, not in accordance with the law, in excess of statutory authority, or divergent from the agency's own rules. View "Warren Livestock, LLC v. Board of County Commissions" on Justia Law

High Plains Power, a cooperatively owned utility in central Wyoming, proposed a tariff revision to the Wyoming Public Service Commission (PSC) in August 2022. The revision aimed to change the compensation rate for customer-generators—members who generate electricity through small net metering systems—from a retail rate credit to an avoided cost rate, which is lower. Powder River Basin Resource Council and Wyoming Outdoor Council opposed this change, arguing it would unfairly reduce compensation for customer-generators.The PSC held a hearing in May 2023, where both parties presented evidence and testimony. The PSC approved the tariff revision on a two-to-one vote, with Chairman Throne dissenting. The appellants then petitioned the district court for review, which certified the case to the Wyoming Supreme Court.The Wyoming Supreme Court reviewed the case de novo and found that the PSC misinterpreted the relevant statute and failed to perform its ratemaking function. The court held that the PSC erred in presuming that the avoided cost rate was a just and reasonable rate for monthly compensation under Wyoming Statute § 37-16-103(a)(iii). The court emphasized that the statute does not specify the value of monthly credits or compensation, leaving it to the PSC to determine through its ratemaking process. The court concluded that the PSC did not evaluate the evidence or consider whether the proposed change served the public interest. Consequently, the Wyoming Supreme Court reversed the PSC's decision. View "Powder River Basin Resource Council v. Wyoming Public Service Commission" on Justia Law

In two separate cases, employees Terry J. Leal and Dustin Kopp sought workers' compensation benefits for injuries they claimed were work-related. Ms. Leal's claim involved a right shoulder injury, while Mr. Kopp's claim involved an abdominal hernia. Both claims were initially denied by the Wyoming Department of Workforce Services, Workers’ Compensation Division, which concluded that the injuries were not caused by their work activities. The employees contested these decisions, leading to hearings before the Office of Administrative Hearings (OAH).In both cases, the OAH appointed attorneys to represent the employees. These attorneys hired medical experts to testify on the causation of the injuries. Ms. Leal's attorney hired Dr. Gregory Reichhardt, and Mr. Kopp's attorney hired Dr. Douglas Adler. The OAH found in favor of the employees, awarding them workers' compensation benefits. However, when the attorneys sought reimbursement for the medical expert fees, the OAH denied these requests, citing a lack of statutory authority under the Wyoming Worker’s Compensation Act to order such reimbursements.The employees appealed to the District Court of Laramie County, which certified the cases to the Wyoming Supreme Court. The Wyoming Supreme Court reviewed whether the OAH had the authority to order reimbursement of medical expert fees. The Court concluded that the OAH does have such authority. It reasoned that the Wyoming Worker’s Compensation Act, when read as a whole, provides for the payment of costs, including expert witness fees, to ensure the quick and efficient delivery of benefits to injured workers at a reasonable cost to employers. The Court found that the OAH's decision to deny reimbursement was not in accordance with the law and reversed the OAH's decision. View "Leal v. State of Wyoming, ex rel. Department of Workforce Services" 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

Ming Zheng, a drilling field engineer, suffered a work-related injury to her right ankle while attempting to disassemble a tool string. She reported the injury and received workers' compensation benefits. Approximately a year later, Zheng sought additional benefits for an injury to her left ankle and requested preauthorization for surgery on her right ankle. The Wyoming Department of Workforce Services, Workers' Compensation Division, denied these requests, finding the treatments were not related to her original work injury. The Division also discontinued her temporary total disability benefits after she received a 0% impairment rating.The Wyoming Medical Commission upheld the Division's denial of benefits and discontinuation of temporary total disability benefits after a contested case hearing. The Commission found that Zheng failed to prove the requested treatments for her left ankle were related to her compensable work injury and that the surgery on her right ankle was necessary. The district court affirmed the Medical Commission's decision.The Wyoming Supreme Court reviewed the case and affirmed the lower court's decision. The Court held that substantial evidence supported the Medical Commission's findings that Zheng's left ankle issues were not related to her work injury and that the requested surgery on her right ankle was not necessary. The Court also found that the Medical Commission did not act arbitrarily or capriciously in admitting an addendum to Dr. Orth's independent medical evaluation, as Zheng had the opportunity to cross-examine Dr. Orth and present rebuttal evidence. The Court concluded that the Medical Commission's decision was supported by substantial evidence and was not arbitrary or capricious. View "Zheng v. State of Wyoming, Ex Rel. Department of Workforce Services" on Justia Law

The case revolves around Gracie and Jeff Richardson, the legal guardians of their adult son, JMR, who suffers from severe developmental and intellectual disabilities. JMR requires full-time care and receives the highest level of Medicaid benefits offered through the Home and Community Based Services Waiver Program (HCBS Program) administered by the Wyoming Department of Health. The HCBS Program offers numerous services to participants like JMR to meet their individually assessed needs. In 2017, the Department entered into a settlement agreement with the Richardsons to establish an individual plan of care for JMR that permitted him to spend his individual budget amount on adult day services, residential habilitation services (community living services), and respite services.In 2021, the Department reviewed JMR’s individual plan of care pursuant to a quality improvement review. The Department discovered JMR’s providers had been billing for respite services at the same time JMR had been receiving community living services. Under the Department’s Comprehensive and Supports Waiver Service Index (the Index), providers are not authorized to bill for both the daily rate of community living services and the fifteen-minute units of respite services. The Department, relying on the Index, notified the Richardsons that it was required to remove respite services from JMR’s individual plan of care. The Richardsons requested an administrative hearing, which upheld the Department’s decision. The Richardsons appealed to the district court, which affirmed the decision. The Richardsons then appealed to the Supreme Court of Wyoming.The Supreme Court of Wyoming affirmed the lower court's decision. The court found that the Department acted in accordance with law when it removed respite services from JMR’s individual plan of care. The court held that the Index, which was incorporated by reference in the Department’s Medicaid regulations, constituted a rule with the force and effect of law. The court also found that the Department’s quality improvement review, which was used to identify the billing deemed erroneous under the Index, was not considered a “rule” under the Wyoming Administrative Procedure Act and therefore did not require the rulemaking process before implementation. Finally, the court concluded that the Department’s removal of respite services from JMR’s individual plan of care did not violate the parties’ 2017 Settlement Agreement. View "Richardson v. State of Wyoming, Ex Rel. Wyoming Department of Health" on Justia Law