Justia Wyoming Supreme Court Opinion Summaries

Plaintiff filed a declaratory judgment action against the Teton County Assessor seeking a declaration that the trusts for which it acted as trustee were charitable trusts within the meaning of Wyo. Stat. Ann. 4-10-406(a) and were exempt from taxation under Wyo. Stat. Ann. 39-11-105(xix). The district court dismissed the complaint, concluding that the primary jurisdiction doctrine made dismissal of the action appropriate. The Supreme Court affirmed, holding (1) because Plaintiff failed to exhaust its administrative remedies before filing a complaint in the district court, the district court properly dismissed the complaint; and (2) to the extent Plaintiff may have properly invoked the district court’s jurisdiction the district court did not abuse its discretion in concluding that the primary jurisdiction doctrine warranted dismissal of the action in favor of review through the administrative process. View "Thomas Gilcrease Foundation v. Cavallaro" on Justia Law

The Wyoming Workers’ Compensation Division covered the surgery on Jeffrey Baker’s shoulder, which was injured at work. The Division, however, denied Baker’s subsequent request for temporary total disability benefits related to a neck injury Baker claimed occurred with the shoulder surgery. The Medical Commission Hearing Panel denied Baker’s claim on review, determining that Baker failed to prove a causal relationship between his neck injury and the work-related accident. The district court upheld the decision of the Commission. The Supreme Court affirmed, holding that the Commission’s determination was supported by substantial evidence. View "Baker v. State ex rel. Department of Workforce Services" on Justia Law

Clare Sikora filed a declaratory judgment action against the City of Rawlins challenging the City’s issuance of a building permit to her next-door neighbors, Jared and Kasandra Ramsey. The district court ruled in favor of the City. The Supreme Court affirmed, holding (1) the district court properly found that Sikora failed to exhaust her administrative remedies; and (2) the district court did not err in finding that the the municipal ordinance governing restoration of a nonconforming building allows for demolition of the nonconforming building and reconstruction of the building within the same footprint - the type of construction undertaken by the Ramseys. View "Sikora v. City of Rawlins" on Justia Law

In 2013, Karen Hardy was injured during the course of her employment. In 2015, Hardy sought treatment for low back pain. The Department of Workforce Services, Workers’ Compensation Division denied payment for Hardy’s medical bills. The Office of Administrative Hearings (OAH) concluded that Hardy’s injury was not compensable because Hardy had failed to prove by a preponderance of the evidence a causal connection between her 2013 work-related injury and her 2015 back injury. The district court affirmed. Hardy appealed, arguing that she was entitled to benefits under the second compensable injury rule. The Supreme Court affirmed, holding that substantial evidence supported the OAH’s conclusion that Hardy failed to demonstrate that it was more probable than not that her 2013 injury was causally related to her 2015 injury. View "Hardy v. State ex rel. Department of Workforce Services, Workers’ Compensation Division" on Justia Law

The State filed a petition alleging that Mother had neglected her two children. Mother admitted to the allegations of the neglect petition and agreed to complete a Department of Family Services (DFS) case plan. The State eventually filed a petition to revoke the consent decree. The juvenile court found the children to be neglected children and ordered that DFS would have legal and physical custody of the children. This appeal concerned the juvenile court’s order changing the permanency plan from reunification to adoption. The Supreme Court affirmed, holding (1) the juvenile court did not commit plain error when it did not make a determination prior to the hearing regarding the children’s attendance at the permanency hearing; (2) Mother was not denied due process of law when the permanency hearing was held without the children; and (3) there was sufficient evidence to support the juvenile court’s decision to change the permanency plan from reunification to adoption. View "ST v. State" on Justia Law

In 2004, Appellant suffered a work-related injury. Appellant had shoulder surgery the next year, and the surgery was covered by the Wyoming Workers’ Compensation Division. In 2013, Appellant sought benefits for surgery on the same shoulder. During the 2013 surgery, Appellant’s surgeon found a hole in the fascia over Appellant’s acromioclavicular joint that may have occurred during the 2005 surgery. Appellant claimed that the 2013 surgery was a second compensable injury, but the Division denied her claim. On appeal, the Medical Commission concluded that there was no causal link between Appellant’s work-related injury and the need for her 2013 surgery. The district court affirmed. The Supreme Court affirmed, holding that the Commission’s conclusion that Appellant’s medical treatment was not compensable was supported by substantial evidence. View "Price v. State, ex rel., Department of Workforce Services, Workers' Compensation Division" on Justia Law

After Crook County Weed and Pest Control District applied herbicides to control leafy spurge found on property owned by Bush Land Development Company and Victoria Bush (collectively, Bush), many trees in the area of the spraying died. Bush filed this inverse condemnation action in the district court alleging that it was entitled to just compensation for the loss of its trees as a result of the District’s improper application of herbicides. The district court dismissed Bush’s claim, concluding that the action was not proper under the inverse condemnation statute. The Supreme Court affirmed on other grounds, concluding that the inverse condemnation was not properly before the district court because Bush failed to exhaust its administrative remedies before claiming inverse condemnation. View "Bush Land Development Co. v. Crook County Weed & Pest Control District" on Justia Law

Appellant, a coal producer that reports the taxable value of its coal to the Department of Revenue using the proportionate profits valuation method, challenged two of the Departments determinations, arguing (1) the Department improperly applied Wyoming law when it set the point of valuation for its coal for production years 2009 through 2011; and (2) the Department improperly categorized certain government-imposed and environmental expenses in the tax valuation formula. The Board of Equalization upheld the Board’s determinations. The Supreme Court affirmed, holding (1) the Board correctly upheld the Department’s decision on the point of valuation; and (2) the Board’s decision on the categorization of the environmental and government-imposed expenses was not final, and the issue was not ripe for judicial review. View "Wyodak Resources Development Corp. v. Wyoming Department of Revenue" on Justia Law

In 2004, KGS was born to Father and Mother. In 2013, a neglect petition was filed against Mother and, after a hearing, KGS was placed in the legal custody of the Department of Family Services. The Department later filed a petition seeking termination of Mother’s and Father’s parental rights. After a hearing, the district court entered an order terminating Father’s parental rights. Father appealed. The Supreme Court affirmed, holding (1) the Department presented sufficient evidence to support termination of Father’s parental rights; and (2) Father failed to show that he was denied due process in this case. View "In re Termination of Parental Rights to KGS" on Justia Law

The City of Torrington brought this action seeking judgment declaring that it was authorized to set rates for electrical services it provided to customers outside the City limits and that it had discretion to utilize revenues from the provision of electricity for other City expenses. The district court (1) determined that the Public Service Commission (PSC) has the exclusive jurisdiction over the rates of the City’s electric utility service provided to customers outside the City’s corporate limits; and (2) declined to rule on the question of whether the City was properly utilizing revenues from the sale of electricity, holding that there was no justiciable controversy regarding that issue. The Supreme Court affirmed, holding (1) the applicable statutes clearly and unambiguously grant the PSC the exclusive power to set rates for electricity provided to customers outside the City corporate limits; and (2) the district court properly declined to rule on the question of the City’s expenditure of electricity revenues. View "City of Torrington v. Smith" on Justia Law