Justia Wyoming Supreme Court Opinion Summaries

Kenneth Cook was terminated from his employment as a sheriff department deputy for violating department policies related to report writing and firearms security. Cook requested a contested case hearing before the sheriff, who upheld Cook's dismissal from the Department. The district court reversed, concluding that the record did not contain substantial evidence demonstrating cause existed to dismiss Cook on the basis of his violation of department policies. The Supreme Court affirmed the district court's decision, holding that the Sheriff's determination that cause existed to discharge Cook on the basis of his violation of department policies was not supported by substantial evidence. View "Laramie County Sheriff's Dep't v. Cook" on Justia Law

Appellant Michael Beall received preauthorization from the Wyoming Workers' Safety and Compensation Division for an orchiectomy, a procedure to remove his left testicle, which he claimed was related to a workplace injury. Beall's employer, Sky Blue Enterprises, objected to the preauthorization and the matter was referred to the Medical Commission Hearing Panel for a contested case hearing. Beall elected to undergo the surgery prior to the scheduled hearing. The Commission denied Beall's claim for reimbursement of medical expenses on the basis that the surgery was not reasonable or necessary medical care resulting from his workplace injury. The district court affirmed. The Supreme Court affirmed, holding (1) the burden of proving that the orchiectomy was reasonable and necessary medical care as related to Beall's alleged workplace injury rested with Beall; and (2) substantial evidence supported the Commission's determination that Beall failed to meet this burden. View "Beall v. Sky Blue Enters., Inc." on Justia Law

Jimmie McMasters was working as an HVAC journeyman when he fell from a beam to a concrete floor and suffered an injury. McMasters applied for permanent total disability benefits claiming a total disability. The Wyoming Workers' Safety and Compensation Division denied the application. The Division did not dispute that McMasters could not return to work but instead contended that McMasters' failure to obtain alternative employment was due to a preexisting psychological condition and a poor effort to find work. The Medical Commission agreed and upheld the denial of benefits. The district court affirmed. The Supreme Court reversed, holding (1) McMasters established a prima facie case under the odd lot doctrine when he showed he could not return to his former employment, and the combination of his psychological and physical conditions precluded alternative employment; (2) the burden thereafter shifted to the Division to show that light work of a special nature, which McMasters could perform, was available; and (3) the Division did not meet its burden. View "McMasters v. State ex rel. Workers' Safety & Comp. Div." on Justia Law

Rebecca Fulmer suffered injuries on two separate dates while working as a nursing assistant at Shepherd of the Valley Care Center. Fulmer submitted worker's compensation claims for both injuries, and the Workers' Safety and Compensation Division denied benefits for the two injuries. The Office of Administrative Hearings (OAH) upheld the denial of benefits, concluding that Fulmer was not entitled to benefits (1) for her first injury because it was the result of Fulmer's own culpable negligence, and (2) for her second injury because it was caused not by her work but by normal activities of day-to-day living. The district court reversed. The Supreme Court affirmed the decision of the district court and held that Fulmer was entitled to benefits for both of her injuries where Shepherd did not meet its burden of proving (1) Fulmer's actions were willful and serious misconduct that constituted culpable negligence with her first injury, and (2) a normal activity of day-to-day living caused Fulmer's hip fracture. Remanded. View "Shepherd of the Valley Care Ctr. v. Fulmer" on Justia Law

In 2008-2009, Scott Davenport sought worker's compensation benefits for medical care and surgery to fuse vertebrae in his lumbar spine. The Workers' Safety and Compensation Division denied benefits on the basis that Davenport's 2008-2009 back problems were not caused by work related injuries Davenport suffered in 1984 and 1985. The Office of Administrative Hearings (OAH) upheld the Division's denial of benefits, ruling that the procedure was necessitated by a preexisting congenital defect in Davenport's lumbar spine and not his prior work related injuries. The district court affirmed the OAH decision. The Supreme Court affirmed, holding that the OAH decision was not against the overwhelming weight of the evidence and was, therefore, supported by substantial evidence in the record. View "Davenport v. State ex rel. Workers' Safety & Comp. Div." on Justia Law

In 2008, the Teton County Commission approved a parcel boundary adjustment application regarding certain real property located in Teton County. Appellees, several individuals, sought judicial review of the Commission's decision. In 2008 and 2009, respectively, Appellants, Mark Menolascino and William Hirshberg, purchased the property. Neither sought to intervene in the judicial review proceedings. In 2011, the reviewing district court reversed the Commission's decision. The parties to the original administrative proceedings declined to appeal the ruling. Appellants, however, filed a notice of appeal. They contemporaneously filed a motion to intervene in the district court proceedings for the sole purpose of pursuing the appeal therefrom. The district court denied their motion to intervene, a decision which Appellants also appealed. The Supreme Court consolidated the appeals and (1) affirmed the district court's denial of Appellants' request to interview in the judicial review proceedings; and (2) dismissed Appellants' appeal of the final order of the district court for lack of standing because of Appellants' status as nonparties. View "Hirshberg v. Coon" on Justia Law

The Wyoming Division of Banking performed a Wyoming Uniform Consumer Credit Code compliance examination of Onyx Acceptance Corporation and determined it was improperly charging its Wyoming customers fees for making payments by telephone or internet. The Division ordered Onyx to stop charging the fees and refund the fees collected. The Office of Administrative Hearings issued a recommended order granting summary judgment for the Division. Consistent with the recommended decision, the administrator of the Code issued an order finding that Onyx violated the Code when it charged the fees. The district court reversed, concluding that the fees were not covered by the Code and, therefore, Onyx did not violate the Code by charging them to customers who opted to pay by phone or internet. The Supreme Court affirmed, holding that Onyx did not violate the Code and summary judgment in its favor was appropriate. Remanded. View "Vogel v. Onyx Acceptance Corp." on Justia Law

This case arose from a decision rendered by the State Board of Equalization (Board) concerning the valuation point for tax purposes of the natural gas production from the LaBarge Field. The Supreme Court remanded the issue to the Board of whether the meters located at the LaBarge Field well sites were "custody transfer meters" as defined by Wyo. Stat. Ann. 39-14-203(b)(iv) or volume meters for Exxon's share of gas production. The Board held (1) the meters were not custody transfer meters for Exxon's share of gas production, and (2) the same meters were custody transfer meters for the gas produced by two other working interest owners, petroleum companies, who were not parties to the action. The Supreme Court (1) affirmed the Board's determination that the meters were not custody transfer meters for Exxon's gas where the Board's determination harmonized with precedent established in Amoco Prod. Co. v. Dep't of Revenue; but (2) reversed the Board's determination that the meters were custody transfer meters for the petroleum companies' gas because the Board did not have the authority to determine the valuation point for "non-party" persons or entities that do not appeal their tax assessments. View "Exxon Mobil Corp. v. Wyo. Dep't of Revenue" on Justia Law

Appellant Steven DeLoge, an inmate in the state penitentiary, was working in the kitchen when he was injured in an altercation with another inmate. Appellant filed a workers' compensation claim based on the injuries sustained from a head-butt from the other inmate. The Wyoming Workers' Safety and Compensation Division (Division) denied the claim. The Office of Administrative Hearings (OAH) concluded that Appellant's injuries were the result of illegal activity and were therefore not compensable under the Wyoming Worker's Compensation Act. The district court affirmed. The Supreme Court affirmed, holding that because the head-butt was a battery under the criminal statute then existing, and therefore an illegal activity, Appellant was not eligible for workers' compensation benefits. View "DeLoge v. State ex rel. Workers' Safety & Comp. Div." on Justia Law

The Wyoming Workers' Compensation Division denied Rick Bodily benefits for medical expenses related to his micro-lumbar discectomy for a herniated disc in his lower back after determining that Bodily's medical treatment was not related to his compensable work-related back injuries. The Office of Administrative Hearings (OAH) granted the Division's motion for summary judgment against Bodily. The district court affirmed. The Supreme Court reversed OAH's summary judgment, holding (1) genuine issues of material fact about causation of Bodily's disc herniation existed; and (2) the OAH erroneously acted as the trier of fact at the summary judgment stage in this case by weighing all the evidence and making credibility determinations. View "Bodily v. State ex rel. Workers' Safety & Comp. Div." on Justia Law