Justia Wyoming Supreme Court Opinion Summaries

Appellant, acting as the personal representative for her deceased mother’s estate, sued Star Valley Medical and Care Centers and several of their employees (collectively, Appellees), alleging that Appellees’ negligence caused her mother’s death. Before filing her complaint, Appellant submitted a governmental claim as required by the Wyoming Governmental Claims Act (WGCA). Appellees filed a motion for summary judgment alleging that Appellant’s claim was defective because it was not signed under oath or penalty of perjury as required by the current WGCA and the Wyoming Constitutions. The district court found that, for these reasons, the claim was invalid and granted summary judgment to Appellees. The Supreme Court reversed, holding (1) the claim requirements set forth in the WGCA and Wyoming Constitution are nonjurisdictional substantive requirements that can be waived; and (2) although the claim in this case did not meet statutory and constitutional requirements, Appellees failed to adequately raise the claim’s deficiencies as an affirmative defense and therefore waived that defense. View "Harmon v. Star Valley Med. Ctr." on Justia Law

Plaintiff, as personal representative for Connie Scribner, filed a wrongful death complaint against Defendants, Dr. Sean Beyer and Emergency Medical Physicians, P.C., alleging that Defendants’ care of Scribner fell below the standard of care. The first trial ended in a mistrial, and a second trial was held. The jury rendered a verdict in favor of Defendants. Plaintiff appealed and Defendants cross-appealed. The Supreme Court affirmed, holding that the district court did not abuse its discretion in declaring a mistrial or in admitting the testimony of Dr. Beyer and Defendants’ emergency medicine expert concerning certain medical tests and a pneumonia severity index. View "Miller v. Beyer" on Justia Law

Gary Carl Stroth became very sick on September 23, 2010 and died a few days later. On October 11, 2012, Appellant submitted a notice of claim against the Star Valley Medical Center (Hospital), the Town of Thayne and the Thayne Ambulance Service, alleging the Hospital and Ambulance Service were negligent in their care of Stroth and that the Town was liable under the doctrine of respondeat superior. The district court dismissed the complaint, concluding that Appellant’s claim had not been timely filed under the Wyoming Governmental Claims Act (WGCA). The Supreme Court affirmed, holding that because Appellant presented her notice of claim more than two years after the accrual of her claim, the district court correctly dismissed her complaint for failure to submit a timely notice of claim under the WGCA. View "Stroth v. N. Lincoln County Hosp. Dist." on Justia Law

Defendant, a contractor, and Plaintiff, a subcontractor, entered into a two subcontracts for part of a road work project. Plaintiff invoiced Defendant for the work under both contracts, but when Defendant failed to pay the full amount, Plaintiff filed suit for breach of contract damages and storage fees for Defendant’s equipment and materials. Defendant counterclaimed, alleging that Plaintiff had been overpaid on the contracts and had converted Defendant’s equipment. Defendant moved to have the matter removed to federal court and filed its counterclaim in that court. The case was subsequently remanded to state court, where Defendant filed its counterclaim. Plaintiff moved for summary judgment, claiming Defendant’s counterclaim was untimely. The district court granted the motion and dismissed the counterclaim. After a bench trial, judgment was entered in favor of Plaintiff. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate any basis to reverse the district court’s dismissal of its counterclaim on summary judgment; (2) alternatively, Defendant’s proposed counterclaim was moot; and (3) Plaintiff was entitled to attorney fees and costs. View "Motzko Co. USA, LLC v. A & D Oilfield Dozers, Inc." on Justia Law

Appellants decided to sell 850 acres of farmland but wanted to retain the mineral rights. Summit Title Services prepared the deeds for the sale, but he deeds did not reserve the minerals. Appellants were made aware of the omission at closing, insisted that the deeds be corrected, and were assured by Summit’s employee that the problem had been rectified. Six years later, Appellants learned that the minerals had been transferred with the land. Appellants filed suit against Summit, its general counsel Olen Snider, and Kuzma Success Realty, a brokerage firm involved in the transaction. The district court granted summary judgment for Appellees on all claims, concluding that Appellants failed to exercise due diligence to discover the error so as to extend the statute of limitation as a matter of law. The Supreme Court reversed the grant of summary judgment to Summit and Snider, concluding that there were genuine issues of material fact as to whether Appellants exercised due diligence to discover errors allegedly made by Summit and that Snider failed to present a prima facie case that he was entitled to summary judgment. View "Moats v. Prof'l Assistance, LLC " on Justia Law

Plaintiffs filed a medical malpractice action against the Campbell County Memorial Hospital under the Wyoming Governmental Claims Act (Act), alleging that Amanda Phillips, a certified nurse anesthetist for Northern Plains Anesthesia Associates, which provided anesthesia services for the hospital, acted as an employee or agent of the hospital, making the hospital vicariously liable for Phillips’ alleged negligence. The hospital filed a motion for partial summary judgment, arguing that a government hospital could not be vicariously liable for acts of non-employees or independent contractors under the doctrine of ostensible agency. The district court denied the motion based on Sharsmith v. Hill. The Supreme Court reversed, holding that the district court erred in its interpretation of Sharsmith and that Sharsmith did not create an implied waiver of sovereign immunity under the Act. View "Campbell County Memorial Hosp. v. Pfeifle" on Justia Law

Pursuant to an oral agreement with Defendant, Plaintiff kept his beefalo cattle herd on Defendant's ranch. After a dispute arose between the parties regarding the oral agreement, Defendant asserted a lien for payments allegedly owed under the oral agreement. Plaintiff filed a complaint and petition for release of his cattle, asserting that the lien was knowingly false and groundless and that Defendant wrongfully converted the beefalo herd. The jury found that Defendant was liable for conversion of Plaintiff's cattle but that Defendant was entitled to the lien claimed for feed and pasturage from the time Defendant asserted the lien on the cattle until their court-ordered release. Defendant filed a motion for a new trial, claiming the verdict was inconsistent because he could not be liable for conversion of Plaintiff's beefalo herd if he was entitled to a lien against the same. The district court denied Defendant's motions and entered a final judgment incorporating the jury's verdict. The Supreme Court reversed, holding that the district court abused its discretion in denying Defendant's motion for new trial because the verdict was contrary to law and could not be reconciled. Remanded for a new trial. View "McTiernan v. Jellis" on Justia Law

Richard Reynolds filed a complaint against Christopher Bonar, claiming personal injuries arising from a motor vehicle accident. Bonar later filed a motion for sanctions for Reynolds' failure to comply with discovery, which the district court granted. Thereafter, Bonar filed a motion to dismiss based on Reynolds' failure to comply with the court's order. The district court granted Bonar's motion and dismissed the complaint without prejudice. Reynolds subsequently re-filed his complaint against Bonar. The district court later dismissed Reynolds' complaint with prejudice for failure to comply with discovery. The Supreme Court affirmed, finding no constitutional violation in the district court's dismissal of Reynolds' complaint with prejudice. The Court also imposed sanctions upon Reynolds. View "Reynolds v. Bonar" on Justia Law

After stepping into a hole drilled in the gutter of a street in the City of Lander, Appellant fell, injuring her hip and back. Appellant sued the City, claiming (1) the City was negligent in the operation of a public utility or service, and (2) she was entitled to recover under Wyo. Stat. 15-4-307, which renders cities and towns liable for injuries resulting from excavations or obstructions that make streets or sidewalks unsafe. The Supreme Court affirmed, holding (1) Appellant's negligence claim was barred both by the absence of an applicable exception to immunity and a specific statutory immunity; and (2) section 15-4-307 does not create a cause of action based on the negligence of public employees of cities and towns for excavations or obstructions of streets. View "Difelici v. City of Lander" on Justia Law

Appellants purchased property that was subject to a Master Plan that restricted the use and development of the property. Appellants obtained title insurance from Insurer, but the policy did not mention the Master Plan. Appellants only later learned of the Master Plan when they were informed they were in violation of the Master Plan and faced substantial penalties if they failed to comply with the Plan. Appellants sued Insurer, claiming a breach of the terms of the title insurance policy, negligence, and bad faith. The district court granted summary judgment in favor of Insurer on all claims brought in Appellants' complaint. The Supreme Court affirmed, holding that the district court did not err in entering judgment in favor of Insurer. View "Sonnett v. First Am. Title Ins. Co." on Justia Law