Justia Wyoming Supreme Court Opinion Summaries

Appellant was injured in an accident that occurred during the course of her employment. After receiving a permanent partial impairment award from the Wyoming Worker's Compensation Division, Appellant sought permanent partial disability benefits. The Division denied Appellant's application, stating that she had not complied with the statutory work search requirements. After a contested case hearing, the Office of Administrative Hearings granted summary judgment for the Division, concluding that Appellant had not timely submitted documentation showing she had sought work. The district court affirmed. The Supreme Court reversed, holding (1) Appellant's work search submission was timely; and (2) Appellant was entitled to a hearing and the opportunity to present evidence showing that she actively sought work. View "Stallman v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

After being arrested for driving while under the influence, Appellant submitted a request for contested case hearing before the Office of Administrative Hearings (OAH) asking the OAH to rule that the procedure used by the arresting officer to conduct the chemical breath test upon which his arrest was based did not comply with Wyo. Stat. Ann. 31-6-105(a) and, therefore, the proposed suspension of his driver's license must be vacated. The OAH hearing examiner upheld the suspension. The district court affirmed. The Supreme Court affirmed, holding (1) it was proper for OAH to apply a presumption that the underlying chemical test result was valid; and (2) Appellant did not present any evidence at the administrative hearing to rebut the presumption that the breath test results were accurate and failed to meet the requirements of Wyo. R. App. P. 12.08 that would allow the Supreme Court to order the additional evidence to be taken before the agency. View "Romsa v. State ex rel. Wyo. Dep't of Transp." on Justia Law

The Wyoming Workers' Safety and Compensation Division issued a final determination awarding Appellant a two percent permanent partial impairment benefit after Appellant was injured in a work-related accident. After a hearing, the Medical Commission upheld the Division's final determination. The district court's issued an order affirming the Medical Commission's decision. The Supreme Court affirmed, holding (1) in light of expert opinions, the criteria set forth in the AMA Guides, Appellant's medical records, and Appellant's symptoms at the time of the hearing, the Medical Commission's findings were supported by substantial evidence; and (2) even if the Court found that the Medical Commission's credibility findings were not supported by the record, substantial evidence would remain to support the Commission's decision. View "Willey v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Petitioner was injured in an accident while driving his motorcycle to work. He filed a claim for worker's compensation benefits asserting that his injuries were covered because he sustained them while traveling to work and his employer reimbursed him for travel expenses. The Wyoming Worker's Compensation Division denied his claim. After a hearing, the Office of Administrative Hearings (OAH) also denied his claim. The district court affirmed the denial. The Supreme Court affirmed, holding that the OAH's conclusion that Petitioner failed to meet his burden of proving he was reimbursed for travel expenses was not contrary to the overwhelming weight of the evidence. View "Bilyeau v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

After Swan Ranch was annexed by the City of Cheyenne in 2009, Appellants, neighbors to the land being annexed, filed a declaratory judgment action against the City alleging that the annexation was invalid under Wyo. Stat. Ann. 15-1-402(a). Ultimately, the district court granted the City's responding summary judgment argument on two claims and conducted trial on the third and final claim. Following trial, the district court found the annexation was proper. The Supreme Court affirmed, holding that the district court's decision upholding the Swan Ranch annexation was not clearly erroneous, as "the degree of contact, the location, and the character of the annexed parcel" were sufficient to satisfy the statutory requirements for annexation under section 15-1-402. View "Hough v. City of Cheyenne" on Justia Law

This appeal involved the issuance by the Wyoming Department of Environmental Qualify (DEQ) of two general permits for the discharge of produced water from coal bed methane operations. A petroleum corporation and oil company (Appellants) appealed the DEQ's decision to the Environmental Quality Council (EQC). The Wyoming Outdoor Council (WOC) also sought review of the DEQ's decision to issue the general permits. The EQC rejected WOC's claim that general permits were rules and had to be promulgated through the rulemaking procedures set forth in the Wyoming APA. The district court reversed, determining that DEQ was required to promulgate the general permits as rules. The district court also rejected the argument by Appellants that WOC was not entitled to seek EQC review of the DEQ's decision to issue the general permits, ruling that the Wyoming Environmental Quality Act did allow WOC to seek administrative review by the EQC. The Supreme Court reversed in part and affirmed in part, holding (1) DEQ was not required to promulgate the general permits as administrative rules; and (2) WOC was entitled to EQC review of DEQ's decision to issue the general permits. View "Wyo. Dep't of Env't Quality v. Wyo. Outdoor Council " on Justia Law

Appellant received disability benefits due to a work-related injury. Those benefits were terminated as a result of Appellant's incarceration. Following his release, Appellant applied for reinstatement of the benefits. Although that application was initially denied, benefits were awarded following a contested case hearing. At that time, Appellant filed one application for retroactive benefits for the period during which his prior claim was contested and two additional applications for separate periods of prospective benefits. The office of administrative hearings denied all three claims for failure to comply with the Wyoming Workers' Compensation Act (Act). The district court affirmed the denial of two of those applications. The Supreme Court affirmed, holding that Appellant's applications for temporary total disability benefits did not comply with the Act because a health care provider did not perform a separate physical examination for each of Appellant's applications as required by the Act. View "Talbot v. State ex rel. Workers' Safety & Comp. Div." on Justia Law

Ricky D. Miller challenged a hearing examiner's order upholding his per se driver's license suspension. In his only issue, Miller argued that his breath test was invalid because Corporal Karr's (the test administrator) operator permit for the test equipment was not valid. Miller argued that the evidence established, and the OAH found, that Corporal Karr did not properly maintain her certification and should have been decertified. Considering the applicable statues and Wyoming's relevant case law under the facts of this case, the Supreme Court concluded that under the DOH's Rules and Regulations for Chemical Analysis for Alcohol Testing, Chapter IV, Section 4, the operator's permit in this case was valid because the state agency had not deemed otherwise and had not notified the permittee. "Certainly, there is tension between the quoted rule and the DOH rule . . . However, we conclude that section 4 is controlling, as suggested by this Court in Miller's earlier appeal." The hearing examiner's decision was affirmed, and Miller's per se driver's license suspension stood. View "Miller v. Wyoming" on Justia Law

After stopping Patrick R. Espinoza for failing to maintain a single lane of travel while driving on Interstate 80 (I-80) in Laramie, an Albany County Sheriff's deputy arrested Mr. Espinoza for driving while under the influence of alcohol. The Wyoming Department of Transportation (WYDOT) suspended Mr. Espinoza's driver's license, and he objected. At the contested case hearing, Mr. Espinoza claimed the deputy was not justified in stopping him. The Office of Administrative Hearings (OAH) upheld the suspension, and the district court affirmed. Upon review, the Supreme Court concluded the deputy had probable cause to stop Mr. Espinoza for the traffic violation and affirmed. View "Espinoza v. Dept. of Transp." on Justia Law

PRG (Father) appealed a district court's order following a jury verdict terminating his parental rights to his four minor children. Father contended that the district court erred when it refused to use his proposed jury verdict form. He also claimed that the State Department of Family Services (DFS) presented insufficient evidence to terminate his parental rights and challenged the district court's denial of his motion for a judgment as a matter of law. Upon review, the Supreme Court found that the special verdict form given to the jury was appropriate and the district court did not abuse its discretion in refusing Father's proposed verdict form. Accordingly, the Court affirmed the district court's decision to terminate Father's parental rights. View "In re Termination of Parental rights to: KMO, DMO, CMO, and AKO" on Justia Law