Justia Wyoming Supreme Court Opinion Summaries

Appellant was injured when she was involved in a motor vehicle accident. The other vehicle involved in the accident, a truck, was listed on two different insurance policies: an Allstate policy issued to Jeremy Lucas and a Mountain West policy issued to Wyoming Electric Company. Appellee, Mountain West, filed a complaint for declaratory judgment, requesting that the district court find Mountain West did not have to cover the truck under the policy. The district court granted summary judgment in favor of Mountain West, finding that the owner of Wyoming Electric had given the truck to Lucas and, therefore, the truck was no longer covered under the company's insurance policy. The Supreme Court affirmed, holding that although the truck was titled and registered in the name of Wyoming Electric and was still listed as a specific vehicle on the Mountain West Policy, Mountain West was not required to pay under the policy because, on the date of the accident, Wyoming electric no longer owned the truck and the truck was no longer covered under the Mountain West insurance policy. View "Mendenhall v. Mountain W. Farm Bureau Mut. Ins. Co." 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

Appellees, Shari and Steve Skaj, brought suit against Appellant Vincent Rosty to recover damages caused when an idling dump truck that had been driven by Appellant was knocked into gear, pinning Shari against a motor home. Appellant failed to plead or otherwise defend against the allegations in the complaint. The district court subsequently entered default judgment against Appellant and awarded damages to Appellees. The court then denied Appellant's motion to set aside entry of default or for relief from default judgment. On appeal, the Supreme Court affirmed in part and reversed in part, holding (1) Appellant's appeal was timely; (2) the district court did not violate Appellant's due process rights, as Appellant had adequate notice of the default judgment hearing and thus had a meaningful opportunity to be heard at the hearing; (3) Appellant was properly served with the summons and complaint; (4) the district court did not abuse its discretion by denying Appellant's motion to set aside entry of default and default judgment; and (5) the district court abused its discretion in awarding punitive damages, as Appellees failed to produce sufficient evidence of Appellant's wealth or financial condition to support an award of punitive damages. Remanded. View "Rosty v. Skaj" on Justia Law

Appellant was physically injured as a result of an accident caused by an underinsured motorist. Prior to the accident, Appellant purchased a Dairyland Insurance Policy through his insurance agent, Jonathan Schrack. Although Appellant requested full coverage, the policy did not include underinsured motorist coverage. When the other driver's insurance did not fully cover Appellant's damages, Appellant sued Dairyland and Schrack (Defendants), raising numerous theories as to why he should recover under the Dairyland policy. The district court granted Defendants' motions for summary judgment. The Supreme Court affirmed, holding, inter alia, (1) Wyoming's uninsured motorist statutes unambiguously do not require insurers to provide underinsured motorist liability coverage; (2) Appellant's failure to read the policy was available as a defense to Defendants as to Appellant's negligence and contract claims against them and barred application of the doctrine of promissory estoppel; and (3) the doctrine of reasonable expectations was not available to alter the unambiguous terms of the policy. View "Broderick v. Dairyland Ins. Co." on Justia Law

Randall and Carmen Sinclair brought an action against the City of Gillette asserting three claims for relief, including a claim for damages under the Wyoming Governmental Claims Act. The Act provides broad governmental immunity from tort liability but also establishes a number of specified exceptions. The City asserted governmental immunity and moved to dismiss that claim. The district court granted the motion. The Supreme Court affirmed the district court's order dismissing the claim, holding that the court did not err in finding the Sinclairs' claim was not cognizable under the exception to immunity specified in the Act that allows claims for public employees' negligence while acting within the scope of their duties in the operation of public utilities and services because, in this case, the City's negligence was unrelated to the operation of the storm drain. View "Sinclair v. City of Gillette" 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

Employee slipped and fell while taking out garbage for Employer. Employee was diagnosed with injuries to her right hip, shoulder, and elbow and received workers' compensation benefits for her shoulder injury and an umbilical hernia. After Employee experienced continuing shoulder pain, an MRI and x-rays of Employee's cervical spine were ordered. The Wyoming Worker's Safety and Compensation Division denied Employee reimbursement of the payments for those medical expenses on the grounds that injuries to the cervical spine were not the result of a work-related injury. The Office of Administrative Hearings upheld the Division's decision, and the district court affirmed. The Supreme Court affirmed, holding that it was reasonable for the hearing examiner to conclude, based upon substantial evidence in the record, Employee had not met her burden of establishing that, although the condition of her cervical spine may have been causing shoulder pain, any damage to the cervical spine was not a result of her slip and fall. View "Price v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Appellants, Timothy Araguz and James Elder, were injured in separate incidents while working at the Wal-Mart Distribution Center. After receiving compensation through Wal-Mart's private workers' compensation fund, Appellants filed for benefits under the Wyoming Worker's Compensation Act. The Wyoming Workers' Safety and Compensation Division denied their request, and the Office of Administrative Hearings confirmed the denial. At issue on appeal was whether Appellants were engaged in extrahazardous employment as defined by Wyo. Stat. Ann. 27-14-108. The Supreme Court affirmed the denial of benefits, holding that Wal-Mart was not engaged in extrahazardous employment as defined by the legislature and, therefore, Appellants were not entitled to workers' compensation benefits. View "Araguz v. State ex rel. Workers' Safety & Comp. Div." on Justia Law