Justia Wyoming Supreme Court Opinion Summaries

Appellant was arrested for driving under the influence of a controlled substance (DUI) after he was stopped for failing to use his turn signal. Appellant refused to submit to chemical testing. The Wyoming Department of Transportation subsequently suspended Appellant's driver's license for six months. The Office of Administrative Hearings (OAH) upheld the suspension. The district court affirmed. The Supreme Court reversed the OAH order upholding the suspension of Appellant's driver's license, holding that the OAH's conclusion that probable cause existed to arrest Appellant for DUI was clearly contrary to the overwhelming weight of the evidence. View "Vogt v. State ex rel. Dep't of Transp." on Justia Law

In 2004, Appellant suffered an injury to his lumbar spine while in the course and scope of his employment. Appellant applied for and received workers' compensation benefits for the injury. In 2005, Appellant accepted compensation for twenty-one percent whole body permanent partial impairment (PPI). After Appellant underwent additional surgery to his lumbar spine in 2010, Appellant received a final rating of seven percent whole body PPI. Because the 2010 PPI evaluation resulted in a rating that was less than the 2005 rating, the Workers' Compensation Division denied a PPI award beyond the twenty-one percent already paid. The Medical Commission upheld the Division's determination. The district court affirmed. The Supreme Court affirmed, holding that the Commission's decision denying Appellant's request for a higher PPI rating was in accordance with law, was supported by substantial evidence, and was not arbitrary and capricious. View "In re Worker's Comp. Claim of Green" on Justia Law

Western Wyoming Construction Company (WWC) submitted a bid for a highway project in Sublette County. The Board of County Commissioners of Sublette County (Commissioners) awarded the contract to another resident contractor whose bid was higher than WWC's. WWC filed a complaint in district court for an order awarding it the contract for the project. The district court granted summary judgment in favor of the Commissioners. At issue on appeal was whether Wyo. Stat. 16-6-102(a) required the Commissioners to award the contract to the responsible certified Wyoming resident making the lowest bid. The Supreme Court reversed, holding (1) section 16-6-102 has no application in the context of two resident contractors; and (2) because no evidence was presented showing where the funds came from to pay for the project, (i) there could be no finding as to what statutory provision, if any, was applicable, and (ii) a judicial determination as to the appropriateness of the bid award was not possible. Remanded. View "W. Wyo. Constr. Co., Inc. v. Bd. of County Comm'rs" on Justia Law

The Wyoming Workers' Safety and Compensation Division awarded benefits to Appellant after he experienced a workplace injury. The Division denied Appellant's claim for payment for prescription medication he alleged was related to his workplace injury. The Medical Commission upheld the Division's determination, and the district court affirmed. The Supreme Court affirmed, holding (1) the Commission's decision upholding the Division's denial of benefits was supported by substantial evidence; and (2) the Commission applied the proper burden of proof for a second compensable injury when it required Appellant to establish a causal connection between his abdominal pain and his ingestion of the prescription medication at issue. View "Jacobs v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Appellant was charged while driving under the influence. The Wyoming Department of Transportation suspended Appellant's driver's license. Appellant appealed, arguing that she had not been properly advised as to implied consent. The Office of Administrative Hearings upheld the suspension. Appellant sought review of the administrative suspension in the district court, raising a number of constitutional challenges to a municipal criminal ordinance in addition to the claim that she had not been properly advised under the implied consent statute. The district court concluded (1) the constitutional issues raised by Appellant had not and could have been raised in the administrative hearing, and therefore, the court lacked jurisdiction to consider the claims; and (2) Appellant was properly advised as to implied consent. The Supreme Court affirmed, holding (1) the hearing officer correctly determined that Appellant was properly advised as required by statute; and (2) Appellant's other claims were not and could have been presented in a license suspension proceeding. View "Walters v. State ex rel. Wyo. Dep't of Transp." on Justia Law

The manager of the Wyoming Universal Service Fund (WUSF) filed confidential reports with the Wyoming Public Service Commission (PSC) containing his recommendations for the WUSF assessment level for fiscal years 2009 and 2010. Upon notice from the PSC that public hearings would be held to consider the manager's reports, Qwest asked for contested case hearings. The PSC denied Qwest's requests, concluding that WUSF proceedings are legislative in nature. The PSC subsequently issued orders establishing the WUSF assessment levels as recommended by the manager. The Office of Consumer Advocate and Qwest filed petitions for review of the PSC order. The district court held that the PSC erred in denying Qwest's requests for contested case hearings, reversed the administrative orders, and ordered portions of the 2009 data to be provided to Qwest but denied the request for 2010 data. Four notices of appeal from the district court's order were filed. The Supreme Court affirmed, holding that Qwest was entitled to contested case hearings before the PSC. Remanded for contested case hearings. View "Pub. Serv. Comm'n of Wyo. v. Qwest Corp." on Justia Law

Appellant injured her neck and shoulder in a work-related accident. The Workers' Safety and Compensation Division approved Appellant's application for temporary total disability benefits but denied payments of two medical bills related to Appellant's lower back, concluding that the case was only left open for shoulder and neck injury. The office of administrative hearings (OAH) upheld the Division's denial of benefits. Appellant appealed. While on review in the district court, Appellant's counsel discovered documentation of a physical therapy session held approximately one month after Appellant's workplace accident that indicated she was experiencing pain in the middle of her back. Appellant unsuccessfully filed a motion to supplement the record with the physical therapy record. Appellant subsequently dismissed her appeal. Appellant then filed a Wyo. R. Civ. P. 60(b) motion for relief from final judgment based on the physical therapy record. The OAH denied the motion. The district court affirmed. The Supreme Court affirmed, holding (1) Appellant provided no evidence to support her claim that the failure to introduce the physical therapy record was caused by her trial counsel's mistake or inadvertence, and (2) Appellant failed to prove the significance of the medical record to her claim for benefits relating to her low back. View "Tegeler v. State ex rel. Workers' Safety & Comp. Div" on Justia Law

The Wyoming Oil and Gas Conservation Commission approved Cimarex Energy Company's plan to reinject waste carbon dioxide and hydrogen sulfide into a producing natural gas formation in southwest Wyoming over the objection of Exxon Mobil Corporation. Exxon appealed. The district court affirmed the Commission's decision. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the Commission properly denied Exxon's petition for a rehearing; but (2) the Commission failed to provide sufficient findings of fact as to whether Cimarex's plan to reinject carbon dioxide and hydrogen sulfide would result in waste of natural gas and improperly interfere with Exxon's correlative rights. Remanded to the Commission to make appropriate findings of both basic and ultimate facts. View "Exxon Mobil Corp. v. Wyo. Oil & Gas Conservation Comm'n" on Justia Law

Appellant, who worked for the Wyoming Department of Corrections, sustained significant injuries during a vehicle rollover while driving to pick up a prisoner. The Workers' Safety and Compensation Division awarded Appellant a partial impairment award, after which Appellant applied for permanent total disability (PTD) benefits. The Division denied her application, finding that she did not meet the statutory definition of PTD. The Medical Commission concluded that Appellant did not meet her burden of proving that she was entitled to PTD benefits. The district court affirmed. The Supreme Court reversed, holding that Appellant presented a prima facie case showing that she was unemployable in her community due to her injuries, and the Division failed to rebut this showing by demonstrating that there was in fact gainful employment available to her within a reasonable geographic area. Remanded. View "Stallman v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Appellee sustained a compensable neck injury and, despite four separate surgeries to address it, never returned to work. The Workers' Safety and Compensation Division paid Appellee temporary total disability (TTD) benefits for thirty-six months, the maximum period allowed by Wyo. Stat. Ann. 27-14-404(a) and the Division's rules. The Office of Administrative Hearings (OAH) awarded additional TTD benefits to Appellee, finding that each of Appellee's four separate surgeries was a second compensable injury, thus extending the amount of time the Division could pay TTD benefits. The district court affirmed the OAH's orders, and the Division appealed. The Supreme Court reversed and remanded, holding (1) under section 27-14-404(a) and the Division's rules, receipt of temporary total disability benefits is limited to a maximum period of thirty-six months; (2) under section 404(a), this limitation applies to all injuries resulting from any one incident or accident, encompassing situations in which the claimant receives multiple injuries simultaneously or a subsequent compensable injury as the result of a single workplace accident; and (3) because Appellee received benefits for a period of thirty-six months as a result of a single workplace accident, he was not entitled to receive additional TTD benefits. View "State ex rel. Wyo. Workers' Safety & Comp. Div. v. Smith" on Justia Law