Justia Wyoming Supreme Court Opinion Summaries

RB was injured when he and his friends were running and sliding on a patch of ice on the sidewalk between buildings at Greybull Middle School. RB sued Big Horn County School District No. 3, alleging that the school district was negligent for failing to remove the ice that had accumulated on the sidewalk. The district court granted summary judgment in favor of the school district on the question of whether there was a duty, concluding that the accumulation of ice in this case was both obvious and natural. The Supreme Court affirmed, holding that RB could not establish a prima facie case of negligence because the school district had no duty under either the natural accumulation rule or based on Greybull’s snow removal ordinance. View "RB, Jr. v. Big Horn County School District No. 3" on Justia Law

In February 2011, two years and four months after Plaintiff learned she had been disinherited by her mother, Plaintiff filed a complaint against financial advisor Bradley Lott for fraud and constructive fraud. A jury found that Lott had committed constructive fraud but that Plaintiff knew or should have known before February 2007 that the fraud occurred. Based on the jury’s findings, the district court dismissed the action, concluding that Plaintiff’s claims were barred by the statute of limitations. The Supreme Court reversed the judgment, holding (1) the evidence did not support a finding that Plaintiff could have discovered the fraud sooner, and (2) therefore, the district court erred by dismissing the case based on the statute of limitations. Remanded for a new trial.View "Erdelyi v. Lott" on Justia Law

Robert Carson and his passenger, Hugh Sharp, were involved in a car accident in which Carson sustained multiple injuries and Sharp was killed. Carson filed a claim for worker’s compensation benefits. The Wyoming Workers’ Safety and Compensation Division denied benefits, finding that Carson’s injuries did not arise out of and in the course of his employment with Metrocities Mortgage, LLC. The Office of Administrative Hearings (OAH) upheld the denial of Carson’s claim. Meanwhile, Sharp’s widow filed a wrongful death action against Carson and Metrocities. After a trial, a federal jury entered judgment against Metrocities under the theory of respondeat superior, concluding that Carson was acting within the course of scope of his employment when the accident occurred. On the basis of the federal judgment, Carson submitted a motion to reopen his claim with the OAH, contending that there was newly discovered evidence he was acting within the course of his employment at the time of the accident. The OAH eventually affirmed its earlier decision. The Supreme Court affirmed, holding that the OAH did not err when it failed to apply collateral estoppel to the issue of whether Carson was in the course and scope of his employment at the time of his injury.View "Carson v. State ex rel., Wyo. Workers' Safety & Comp. Div." on Justia Law

In 2011, Decedent died of injuries incurred in an automobile accident. Decedent was survived by his allegedly estranged wife, Laura Soran, and by his parents and sister. Decedent’s father, in his capacity as personal representative, brought a wrongful death claim brought against Robert Curran, the driver of the vehicle in which Decedent was a passenger when he died, and settled with Curran’s insurance providers for $400,000. A dispute subsequently arose between Decedent’s beneficiaries as to how the settlement proceeds should be distributed. The district court awarded Laura seventy-five percent of the settlement proceeds and divided the remainder among Decedent’s parents and sister. The Supreme Court reversed, holding that the district court’s distribution order was clearly erroneous in that it misapplied the burden of proof and improperly presumed damages in favor of Decedent’s wife where Decedent’s marital relationship was uncertain. Remanded.View "In re Wrongful Death of Daniel P. Soran" on Justia Law

Margaret Reynolds and Jean Moore were involved in a car accident in which Margaret was injured. Jean was employed by Judith and Wilford Jaeger at the time of the accident. Margaret and her husband (the Reynolds) filed a complaint against Moore and the Jaegers, alleging negligence claims against Moore and respondeat superior claims against the Jaegers. The district court dismissed the Reynolds’ complaint, concluding (1) Moore was not sufficiently served for the court to obtain jurisdiction; and (2) Plaintiffs’ claims against the Jaegers were derivative of the claims asserted against Moore and could not be maintained in Moore’s absence. The Supreme Court reversed, holding (1) the district court erred by dismissing the Reynolds’ action against Moore, as Moore was properly served; and (2) because Moore’s dismissal was improper, the claim against the Jaegers should not have been dismissed. Remanded.View "Reynolds v. Jaeger " on Justia Law

Johanna Hicks died from an accidental overdose of her medications. Hicks’ estate filed suit against the doctor who treated Hicks for severe chronic pain for negligently causing Hicks’ death and filed suit against the doctor’s employer, claiming it should be held vicariously liable for the doctor’s negligence. A jury found that the doctor was not negligent in his treatment of Johanna and returned a defense verdict. On appeal, the estate argued that the district court erred by permitting the doctor and his codefendant to introduce the testimony of two expert witnesses on the doctor’s adherence to the appropriate standard of care for practitioners of pain medicine. The Supreme Court affirmed, holding that the estate failed to preserve for appellate review the issue regarding the admissibility of the testimony of the two standard of care experts.View "Hicks v. Zondag" on Justia Law