Justia Wyoming Supreme Court Opinion Summaries

Jerome Knight, who was employed by M&M Welding Services, LLC, and his supervisor, Victory McCoy, who was one of the owners of M&M, were killed in an automobile accident. McCoy was driving the vehicle when the accident occurred. Plaintiff, as Decedent’s personal representative, filed a wrongful death action against the McCoy Estate and M&M. The district court granted summary judgment as to claims against M&M on grounds of employer immunity under the Wyoming Worker’s Compensation Act. The court then granted summary judgment in favor of the McCoy Estate on grounds of defective service of process, lack of personal jurisdiction, and expiration of the statute of limitations. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) correctly concluded that M&M’s employer immunity under the Wyoming Worker’s Compensation Act barred Plaintiff’s wrongful death action against M&M; but (2) erred in determining that Plaintiff’s action against the McCoy Estate was barred by the statute of limitations. View "Knight v. Estate of McCoy" on Justia Law

Appellant, the manager of the Dubois branch of the Fremont County Library System (FCLS), used an FCLS account to order books for the Dubois school system. The FCLS executive director terminated Appellant, determining that Appellant had improperly used FCLS funds to purchase books for the District. The FCLS Board of Trustees upheld the termination based upon an erroneous belief that Appellant had violated Wyo. Stat. Ann. 9-13-105. The district court affirmed, concluding that the Board misread section 9-13-105 but that because Appellant’s employment was at-will, Appellant’s employment may be terminated at any time with or without cause. The Supreme Court affirmed, holding that, as an at-will employee, Appellant did not have a property interest in continued employment or a right to a contested case hearing. View "Sabatka v. Bd. of Trs. of the Fremont County Pub. Library Sys." on Justia Law

David Hartmann was injured during the course of his employment. After receiving surgery for his injury, Hartmann began experiencing dizzy spells. The Wyoming Workers’ Safety Compensation Division denied payment for the treatment Hartmann received for the dizziness. The Office of Administrative Hearings (OAH) found that Hartmann failed to prove a causal link between his dizzy spells and his work injury. The district court reversed, concluding that the OAH failed to apply the second compensable injury rule. The Division appealed. The Supreme Court affirmed the district court’s order to the extent it held the OAH failed to apply the second compensable injury rule but reversed the order remanding the case to the OAH for reconsideration, holding (1) the district court’s ruling was not an appealable order, but it is in the interest of judicial economy to treat the notice of appeal as a petition for review; (2) the OAH failed to invoke and apply the applicable law; and (3) when the applicable law is applied, the OAH decision to reject Hartmann’s evidence is against the overwhelming weight of the evidence. View "State, ex rel., Dep’t of Workforce Servs. v. Hartmann" on Justia Law

In October 2010, Appellant slipped and fell down a flight of stairs outside of her workplace. In January 2011, Appellant was diagnosed with avascular necrosis (AVN) in the femoral head of her right hip. Eventually, the femoral head on her right hip collapsed due to the AVN progression, and in December 2011 Appellant received a total right hip replacement. The Wyoming Department of Workforce Services, Workers’ Safety and Compensation Division denied Appellant’s claim for medical treatment of the AVN, concluding that Appellant’s October 2010 fall did not cause her to then develop AVN. After a contested case hearing, the Office of Administrative Hearings (OAH) agreed and denied benefits. The Supreme Court affirmed, holding that the OAH’s findings of fact and conclusions of law were supported by substantial evidence and were in accordance with the law. View "In re Worker's Compensation Claim of Stevens" on Justia Law

Appellant, an employee of a Harley Davidson service center (Employer), was discharged after working more than five years with Employer. Appellant filed for unemployment benefits. After a hearing, the hearing officer determined that Appellant was not discharged for misconduct connected with his work. The Unemployment Insurance Commission reversed the hearing officer and denied Appellant unemployment compensation benefits, ruling that Appellant was terminated for misconduct. The district court affirmed the Commission. The Supreme Court reversed, holding that the decision of the Commission was unsupported by the record. Remanded with direction that benefits should be restored to Appellant. View "Doggett v. Wyo. Dep’t of Workforce Servs., Unemployment Ins. Comm’n" on Justia Law

Enrique Herrera was working for Gilligan’s LLC under the supervision of Robert Phillipps when he was injured. Herrera was an alien who was not authorized to work in the United States at the time of the injury. Herrera filed a lawsuit against Gilligan’s and Phillips, alleging that Defendants were negligent and that, if that Worker’s Compensation Act applied, Phillipps’ conduct was intentional and he was therefore liable as a co-employee. The district court granted summary judgment for Gilligan’s and Phillipps, concluding primarily that there was no genuine dispute as to the material fact that Defendants reasonably believed Herrera was authorized to work in the United States, and therefore, Defendants were immune from suit pursuant to the Act. The Supreme Court reversed, holding that there was sufficient evidence to raise a genuine issue of material fact as to whether Gilligan’s had a reasonable belief that Herrera was authorized to work in the United States and whether Phillipps acted in intentional disregard of a dangerous condition when he instructed Herrera to perform his work. Remanded. View "Herrera v. Phillipps" on Justia Law

Erin Clements was injured at work and received temporary total disability (TTD) benefits for twelve months. Clements subsequently obtained an extension of TTD benefits for the statutory maximum of twelve months. When Clements applied for additional TTD benefits, the Worker’s Safety and Compensation Division denied her claim because she had received all the TTD benefits to which she was entitled under Wyoming law and Division rules. Clements filed a declaratory judgment action seeking a declaration that the Division exceeded its authority when it limited the extension of TTD benefits to twelve months. The district court granted declaratory relief. The Supreme Court affirmed, holding that the Division exceeded its authority when it adopted a rule setting a maximum number of months TTD benefits are payable under any circumstances. View "State ex rel. Dep’t of Workforce Servs. v. Clements" on Justia Law

In 1994, Appellant suffered modest physical injuries while working as a psychiatric aide at the Wyoming State Hospital. Four years later, Appellant was denied permanent total disability (PTD) benefits. Appellant continued seeking medical treatment. Appellant reapplied for PTD benefits in 2009, but the Wyoming Workers’ Safety and Compensation Division denied her claim. After a case hearing, a panel of the Medical Commission denied the subsequent application for PTD benefits, concluding that Appellant’s only disabling condition was psychological and not related to any compensable physical injury. The district court affirmed. The Supreme Court affirmed, holding that the Commission reasonably concluded that Appellant did not establish entitlement to PTD benefits under the Wyoming Workers’ Compensation Act or the odd lot doctrine, and the Commission’s conclusions were in accordance with applicable law. View "In re Worker's Comp. Claim of Hathaway" on Justia Law

A school district (District) notified Plaintiff, a continuing contract teacher in the District, that his contract would be terminated on grounds of incompetence, insubordination, and poor work performance. Following a hearing, an independent hearing officer concluded that good cause existed for the termination of Plaintiff’s teaching contract and recommended that the contract be terminated for insubordination. The school district board of trustees (Board) accepted the hearing officer’s recommendation and conclusion. Plaintiff appealed, arguing that the Board’s order was entered in violation of the Wyoming Administrative Procedure Act (APA) and his due process rights because some members of the Board did not attend the entire hearing or otherwise review all of the evidence submitted to the hearing officer. The Supreme Court affirmed, holding that the Board did not err by accepting the hearing officer’s recommended decision without independently reviewing the entire evidentiary record received by the hearing officer. View "Wadsworth v. Bd. of Trs. of Lincoln County Sch. Dist. No. Two" 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