Justia Wyoming Supreme Court Opinion Summaries

Bill Kuhl brought wrongful termination claims against his former employer, Wells Fargo Bank, asserting claims for breach of an express contract of employment, breach of an implied contract of employment, promissory estoppel, and tortious breach of the implied covenant of good faith and fair dealing. After the parties engaged in discovery, Wells Fargo moved for summary judgment. Kuhl resisted that motion. After a hearing, the district court granted summary judgment in favor of Wells Fargo. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of Wells Fargo on any of Kuhl's claims. View "Kuhl v. Wells Fargo Bank, N.A" on Justia Law

Catherine Morris submitted a worker's compensation claim for permanent total disability (PTD) benefits, and the Wyoming Workers' Safety and Compensation Division denied her claim. The Wyoming Medical Commission upheld the Division's denial of benefits. The district court affirmed. The Supreme Court affirmed, holding (1) the Commission did not abuse its discretion in admitting a psychological report produced after the discovery cutoff; and (2) the Commission abused its discretion in limiting the scope of Morris' testimony to matters not discussed in the discovery deposition taken by the Division, but Morris did not object below to that limitation and thus waived her right to appeal that issue. View "Morris v. State ex rel. Workers' Safety & Comp. Div." on Justia Law

Soon after Yale Preston was employed by Pennaco Energy, a wholly-owned subsidiary of Marathon Oil Company (collectively referred to as Marathon), Preston signed an employee agreement with a disclosure and assignment of intellectual property clause. The present dispute centered around allegations of patent infringement and questions of ownership of two patents that covered a baffle system that Preston invented. The district court found that Preston was the sole inventor of the patents and that the employee agreement was a valid contract, pursuant to which Preston was required to assign his ownership interest in the patents to Marathon. At issue on appeal was the validity of the assignment of intellectual property rights given to Marathon without an additional consideration other than continued at-will employment. The Supreme Court accepted certification and held that continuing the employment of an existing at-will employee constitutes adequate consideration to support an agreement containing an intellectual property-assignment provision. View "Preston v. Marathon Oil Co." on Justia Law

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

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

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