Justia Wyoming Supreme Court Opinion Summaries

Robert Scherf suffered a heart attack at work while servicing a front end loader. Scherf died of acute myocardial infraction with cardiogenic shock. Claimant, Scherf’s widow, applied for workers’ compensation death benefits. The Wyoming Safety and Compensation Division denied benefits. The Office of Administrative Hearings (OAH) upheld the denial of benefits, concluding that although Claimant had proved a causal link between Scherf’s work exertion and the myocardial infarction, Claimant failed to prove that exertion itself was unusual or abnormal for the particular employment in which Scherf was engaged. The district court affirmed. The Supreme Court reversed, holding that the OAH conclusion that any unusual or abnormal employment exertion Scherf experienced was not unusual to or abnormal for an employee servicing heavy equipment was contrary to the overwhelming weight of the evidence. Remanded for entry of an order awarding benefits. View "Scherf v. State ex rel. Dep’t of Workforce Servs., Workers' Comp. Div." on Justia Law

Appellant had been employed for seven years by the Fremont County School District Number One when the District’s Board of Trustees terminated his employment. On appeal, Appellant asserted that the Board failed to comply with the Board’s rules of practice by untimely making its decision, and because the Board failed to take action within the time set by the rule, the Board lost subject matter jurisdiction to decide the case. The Supreme Court affirmed, holding that even if the decision was untimely, the Board did not lose jurisdiction because the rules do not specify any consequence for non-compliance and there is nothing in the rules to suggest that missing the deadline strips the Board of subject matter jurisdiction. View "Scott v. Bd. of Trs. of Fremont County Sch. Dist. Number One" on Justia Law

Sheri Eaton requested workers’ compensation benefits claiming that she received a workplace injury resulting from an injury at her workplace. After a contested case hearing, the Office of Administrative Hearings (OAH) determined that Eaton did not prove that her injury was related to the workplace event. The OAH also upheld the final determination by the Division ceasing payments for temporary total disability benefits and mental health treatment six months after reaching maximum medical improvement. The district court affirmed the OAH’s decision. The Supreme Court affirmed the district court’s order, holding that the OAH hearing examiner’s decision was supported by substantial evidence and that the OAH’s determination was not arbitrary or capricious. View "Eaton v. State ex rel. Dep’t of Workforce Servs." on Justia Law

Appellant received a back injury while working as a concrete truck driver. Appellant subsequently received two surgeries to his back and could not return to work. The Wyoming Workers’ Safety and Compensation Division assigned Appellant a nine percent permanent partial impairment (PPI) rating. The Medical Commission sustained the Division’s PPI rating. The Supreme Court affirmed, holding that the Medical Commission’s decision that Appellant did not prove he was entitled to a higher impairment rating under the AMA Guides to the Evaluation of Physical Impairment was supported by substantial evidence and otherwise in accordance with the law. View "In re Worker's Compensation Claim of Michael D. Hurt" on Justia Law

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

In 2011, Appellant suffered a work-related injury. The Department of Workforce Services, Workers’ Compensation Division approved benefits for the jury to Appellant’s left groin, abdomen, upper leg, and knee. After Appellant returned to work, he began experiencing back pain. Appellant filed a claim for the evaluation and treatment of his back pain. The Division denied the claim, concluding that the lumbar spine evaluation and treatment Appellant had received were not related to his originally work injury. The Office of Administrative Hearings (OAH) denied Appellant’s worker’s compensation claim on the grounds that he failed to prove a causal relationship between his lower back problems and his work-related accident. The district court upheld the OAH’s decision. The Supreme Court affirmed, holding (1) the hearing examiner’s conclusion that Appellant’s back problem was not caused by the work-related accident was supported by substantial evidence; and (2) the hearing examiner correctly ruled that Appellant was not entitled to worker’s compensation benefits under the second compensable injury rule. View "In re Worker's Comp. Claim of Guerrero" on Justia Law

Sheridan Newspapers, Inc. filed a petition requesting release of minutes reflecting discussion by the Board of Trustees of Sheridan County School District #2 of a proposed multi-purpose recreational facility during executive sessions. In response, the Board asserted that the executive sessions were allowed under the Wyoming Public Meetings Act (WPMA), and the minutes were confidential. After reviewing the minutes in camera the district court entered an order granting summary judgment for the Board, concluding that all issues discussed by the Board during executive session were within the framework of what may be kept confidential pursuant to the WPMA. The Supreme Court reversed, holding that the minutes were so vague as to reveal virtually nothing about the Board’s discussions during executive sessions, and therefore, the minutes were not entitled to confidential treatment. Remanded. View "Sheridan Newspapers, Inc. v. Bd. of Trs." on Justia Law

In 2007, Employee suffered compensable work injuries. Five years later, Employee sought worker’s compensation benefits to cover medical expenses related to his chronic obstructive pulmonary disease (COPD). The Wyoming Workers’ Compensation Division denied benefits on the basis that the COPD was unrelated to Employee’s work injuries. The Office of Administrative Hearings (OAH) upheld the denial of benefits, concluding that Employee’s COPD was a preexisting condition and that Employee had not met his burden of showing that his work injuries materially aggravated his preexisting COPD. The district court affirmed. The Supreme Court reversed, holding that the OAH’s conclusions were not supported by substantial evidence. Remanded for entry of an order awarding benefits. View "Vandre v. State ex rel. Dep’t of Workforce Servs." on Justia Law

Triangle Cross Ranch, Inc. offered help to troubled boys by putting them to work on a cattle ranch that was described as “a Catholic Christian Therapeutic Residential Substance Abuse Treatment Program.” Triangle Cross offered individual counseling and group therapy. The boys’ families paid an admission fee and a monthly tuition. The Wyoming Department of Family Services (DFS) sought an injunction, arguing that Triangle Cross was providing the type of services that required certification, which it had not obtained. After a bench trial, the district concluded that Triangle Cross was offering services that required it to obtain proper licensing and certification and entered an order enjoining Triangle Cross from operating an uncertified child care facility. The Supreme Court affirmed, holding that the district court correctly found that Triangle Cross was offering services to children who are delinquent and thus was required by Wyoming law to obtain certification. View "Triangle Cross Ranch, Inc. v. State" on Justia Law

Dean Hildebrant was working as an HVAC technician at Central Wyoming College in Riverton when he fell from a ladder. The Wyoming Workers’ Safety and Compensation Division found that Hildebrant had suffered a compensable injury as a result of the fall. As part of Hildebrant’s treatment, his doctor recommended the implantation of a spinal cord stimulator in his back. The Division denied preauthorization for the implant. The Office of Administrative Hearings (OAH) upheld the Division’s denial, determining that the implant was premature. The district court affirmed the OAH. The Supreme Court affirmed, holding that there was substantial evidence in the record supporting the OAH’s determination that (1) the proposed treatment was causally related to Hildebrant’s compensable injury, and (2) implantation of a spinal cord stimulator was not medically necessary. View "Hildebrant v. State ex rel., Dep’t of Workforce Servs." on Justia Law