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

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

Appellee was injured while on the job and made a workers’ compensation claim. The Wyoming Division of Workers’ Compensation denied Appellee’s claim for coverage. Appellee later admitted that he provided false documentation in order to secure his employment, that he was a citizen of Mexico, and that he didn’t know if he had permission to work in the United States. After a contested case hearing, the Office of Administrative Hearings (OAH) denied benefits on the grounds that Appellee was not an “employee” as defined in Wyoming’s workers’ compensation statutes. The district court reversed the OAH and awarded Appellee benefits, concluding that the denial of Appellee’s claim for benefits was arbitrary, capricious, an abuse of discretion or otherwise not in accordance with law. The Supreme Court affirmed, holding that the district court did not err in concluding that the OAH’s action was not in accordance with the law and in awarding benefits. View "L & L Enterprises v. Arellano" on Justia Law

Vernon Bailey injured his neck and back while working as a custodial supervisor. The Wyoming Workers’ Compensation Division awarded benefits to Bailey. When Bailey’s symptoms did not improve, a neurosurgeon requested preauthorization for a recommended discectomy and fusion because of neck pain. The Division denied the request. After a hearing, the Medical Commission upheld the Division’s denial of benefits for Bailey’s surgical spine issues. The district court affirmed the Medical Commission. The Supreme Court affirmed, holding that substantial evidence existed to support the Medical Commission’s decision to deny Bailey further benefits for his cervical spine injury. View "Bailey v. State ex rel., Dep’t of Workforce Servs." on Justia Law

While working as the municipal court judge for the town of Diamondville, Wyoming, Appellant slipped and fell on the icy outdoor steps of the town hall. Due to pain in her lower back, Appellant underwent back surgery in 2009. The Wyoming Workers’ Safety and Compensation Division paid for this surgery, along with temporary disability benefits. In 2011, Appellant experienced acute onset of pain in her lower back and left leg. Appellant underwent surgery for a herniated disk. The Division denied coverage for the second surgery, as well as temporary total disability benefits, on the basis that the recent back surgery was not directly related to the work injury. The Office of Administrative Hearings upheld the decision. The district court affirmed. The Supreme Court affirmed, holding that the hearing officer’s decision to deny benefits was supported by substantial evidence and that Appellant failed to show that the decision was arbitrary, capricious, or not in accordance with law. View "Newman v. State ex rel., Dep’t of Workforce Servs." on Justia Law

David Hartmann was injured during the course of his employment. After receiving surgery for his injury, Hartmann began experiencing dizzy spells. The Wyoming Workers’ Safety Compensation Division denied payment for the treatment Hartmann received for the dizziness. The Office of Administrative Hearings (OAH) found that Hartmann failed to prove a causal link between his dizzy spells and his work injury. The district court reversed, concluding that the OAH failed to apply the second compensable injury rule. The Division appealed. The Supreme Court affirmed the district court’s order to the extent it held the OAH failed to apply the second compensable injury rule but reversed the order remanding the case to the OAH for reconsideration, holding (1) the district court’s ruling was not an appealable order, but it is in the interest of judicial economy to treat the notice of appeal as a petition for review; (2) the OAH failed to invoke and apply the applicable law; and (3) when the applicable law is applied, the OAH decision to reject Hartmann’s evidence is against the overwhelming weight of the evidence. View "State, ex rel., Dep’t of Workforce Servs. v. Hartmann" on Justia Law