Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the district court's grant of summary judgment in favor of Plaintiff on his complaint seeking reinstatement of his employment and damages for his wrongful termination and the City of Laramie's failure to reinstate him, holding that the circuit court properly granted summary judgment but erred in denying Plaintiff's motion for costs on the ground that Plaintiff did not include the request in his complaint.The City discharged Plaintiff from his employment as a shift commander in the fire department. The City's Fire Department Civil Service Commission denied its consent to the discharge, and the Supreme Court gave effect to that order. The City did not reinstate Plaintiff, however, and he brought this action seeking reinstatement and damages. The district court ruled that Plaintiff was entitled to reinstatement and awarded him damages of approximately $280,000. The court denied Plaintiff's post-trial motion for attorney fees, costs, and pre-judgment and post-judgment interest. The Supreme Court reversed in part, holding (1) the district court did not err in entering summary judgment for Plaintiff and in denying attorney fees and prejudgment interest; (2) the court did not err when it failed to specify post-judgment interest; and (3) the court erred in denying Plaintiff's request for costs. View "City of Laramie v. Hanft" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Board of Trustees of Laramie County School District Number Two (the Board) dismissing Appellant from his teaching contract with Laramie County School District Number Two (the District) after Appellant disciplined his daughter at school, holding that substantial evidence supported the Board's dismissal decision.At issue was whether district policies and professional conduct standards applied to Appellant, a teacher, who disciplined his child, a student, on school grounds during school hours. The Board concluded that those policies and standards applied to Appellant and dismissed him. The district court affirmed the dismissal and affirmed the Board's decision to pay Appellant only a pro-rata portion of extra-duty pay for coaching track and no bonus following his suspension with pay. The Supreme Court affirmed, holding (1) substantial evidence supported the Board's decision dismissing Appellant; and (2) there was no Board decision on extra-duty or bonus pay for this Court to review. View "Mirich v. State ex rel., Board of Trustees of Laramie County School District Two" on Justia Law

The Supreme Court remanded this case to the district court with instructions to determine whether excusable neglect extended Plaintiff's time to file the petition for review of the decision of the Office of Administrative Hearings (OAH) concluding that Plaintiff's infection was not compensable, holding that the record did not reveal whether the district court considered the question of excusable neglect.Plaintiff scraped his knuckle on a locker as he was getting ready to leave a trona mine, where he worked. The scrape developed necrotizing fasciitis, causing serious injuries. The Department of Workforce Services, Workers' Compensation Division, deemed Plaintiff's injury compensable. The OAH served an order concluding that Plaintiff's injuries were not compensable. The district court reversed, concluding that Plaintiff's infection was compensable. Plaintiff's employer appealed, arguing that the district court lacked jurisdiction because the petition for judicial review was untimely filed. The Supreme Court remanded the case for the limited purpose of determining whether excusable neglect extended the time for filing a petition for review. View "Tata Chemicals Soda Ash Partners, Ltd v. Vinson" on Justia Law

The Supreme Court affirmed the decision of the Department of Workforce Services, Unemployment Insurance Commission denying Jesse Gerber unemployment benefits, holding that the Commission correctly determined that Gerber was not eligible for employment benefits.The Commission determined that Gerber had left work voluntarily without good cause and did not qualify for the "returning to approved training" exception in Wyo. Stat. Ann. 27-3-311(a)(i)(B). The Supreme Court affirmed, holding that Gerber did not meet the conditions of the statutory exception, and therefore, the Commission's decision denying Gerber unemployment benefits conformed with the law. View "Gerber v. State ex rel., Department of Workforce Services" on Justia Law

In this personal injury action brought pursuant to the Workers' Compensation Act the Supreme Court affirmed in part and reversed in part the order of the district court granting summary judgment in favor of one of Plaintiff's co-employee supervisors, holding that genuine issues of material fact existed.Plaintiff was injured when his hand and arm became entangled in a pipe-straightening machine at his place of employment. Plaintiff sued his co-employee supervisors - Elvin Brown, Bill Wartenbee, and Bryce Mitchell - claiming they were not entitled to immunity from liability under the Act because they intentionally acted to cause physical harm or injury to Plaintiff. The district court granted summary judgment for Defendants. The Supreme Court reversed in part, holding (1) Brown and Wartenbee were entitled to judgment as a matter of law and were immune from liability for Plaintiff's injury; and (2) Plaintiff established genuine issues of material fact against Mitchell precluding summary judgment. The Court remanded the claim against Mitchell for trial. View "Ramirez v. Brown" on Justia Law

The Supreme Court affirmed the decision of the Medical Commission upholding that decision of the Wyoming Workers' Safety and Compensation Division denying workers' compensation benefits because Appellant failed to establish a causal connection between his injury and employment, holding that the Commission's decision was not contrary to the overwhelming weight of the evidence.The Division denied benefits because Appellant did not submit evidence establishing a causal connection between his injury and employment as required by Wyo. Stat. Ann. 27-14-603(a). The Commission upheld the denial of benefits after rejecting the opinions of Appellant's medical experts. The Supreme Court affirmed, holding that the Commission's determination that Appellant failed to meet his burden under section 27-14-603(a) for an injury occurring over a substantial period of time was not contrary to the overwhelming weight of the evidence. View "McMillan v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court affirmed the decision of the district court upholding the decision oft he Office of Administrative Hearings (OAH) denying workers' compensation benefits to Appellant, holding that a previous order by the OAH was not a final, appealable order and that collateral estoppel was not applicable.Appellant filed for workers' compensation benefits after his leg was amputated below the knee. The Department of Workforce Services, Workers' Compensation Division (the Division) denied the claim. Appellant appealed, but while the contested case hearing was pending the Division withdrew its denial of benefits. In response, the OAH issued an order vacating the hearing and directing the Division to award workers' compensation benefits. The Division issued a redetermination in favor of Appellant. Appellant's employer objected, and after a contested case hearing, OAH denied workers' compensation benefits. The district court upheld the OAH decision denying benefits. On appeal, Appellant claimed that the first OAH order was a final appealable order awarding benefits and that his employer was collaterally estopped from objecting to the Division's redetermination awarding benefits. The Supreme Court disagreed, holding that the first OAH order was not a "prior adjudication" of workers' compensation benefits and provided no basis to implicate the principle of collateral estoppel. View "Lower v. Peabody Powder River Services, LLC" on Justia Law

The Supreme Court remanded this workers compensation case with instructions to determine whether excusable neglect extended Petitioner's time to file a petition for review of the determination of the Office of Administrative Hearings (OAH) that Petitioner's bacterial infection was not compensable, holding that the district court's decision letter did not address whether excusable neglect extended the time Petitioner had to file his petition for review.Thirty-five days after the OAH concluded that Petitioner's infection was not compensable Petitioner filed a petition for review in the district court. The district court reversed the OAH order. On appeal, Petitioner's employer argued that the district court lacked jurisdiction because the petition was filed one day past the deadline. The Supreme Court remanded the case because the record did not reveal whether the district court considered the question of whether excusable neglect extended the time for filing a petition for review. View "Tata Chemicals Soda Ash Partners, Ltd. v. Vinson" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Office of Administrative Hearings (OAH) upholding the denial of Appellant's application to the Department of Workforce Services, Workers' Compensation Division for permanent partial disability (PPD) benefits, holding that the OAH's decision was not contrary to the overwhelming weight of the evidence.After Appellant injured his back the Division awarded him temporary benefits. When several years had passed without relief from his pain, Appellant appleid for PPD benefits. The Division denied Appellant's application. The OAH upheld the Division's denial of PPD benefits, concluding that Appellant failed to prove his work injury was the cause of his inability to return to employment and failed to prove that he timely filed his PPD application. The Supreme Court affirmed, holding (1) the OAH correctly calculated the limitations period under Wyo. Stat. Ann. 27-14-405(h)(ii); and (2) there was substantial evidence to support the OAH's conclusion that Appellant failed to prove that his injury was the cause of his inability to return to work. View "Camacho v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court reversed the order of the district court affirming the order of the Office of Administrative Hearings (OAH) upholding the Department of Workforce Services, Workers' Compensation Division's (Division) final determination regarding compensability, holding that the OAH erred in its determination that equitable estoppel did not bar the Division from asserting the statute of limitations as a defense.The OAH affirmed the final determination of the Division denying benefits to Appellant on the grounds that Appellant did not file a claim for benefits within the one-year statute of limitations set forth in Wyo. Stat. 27-14-503(a). The Supreme Court reversed, holding that the Division was estopped from asserting the statute of limitations as a defense, and therefore, the OAH's conclusion that section 27-14-503(a) barred Appellant's claim was not in accordance with law. View "Sweetalla v. State ex rev. Department of Workforce Services, Workers' Compensation Division" on Justia Law