Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of numerous charges, including false imprisonment, felonious restraint, and aggravated assault and battery. The Supreme Court affirmed, holding (1) the prosecutor did not suppress exculpatory evidence in violation of Defendant's state and federal due process rights; (2) the district court erred in ordering Defendant to disclose witness statements and in limiting Defendant's cross-examination of two prosecution witnesses as a sanction for failure to comply with that order, but the error was harmless; (3) the prosecutor did not commit misconduct by failing to correct the testimony of two witnesses; and (4) the district court did not commit plain error in its sentencing decisions and orders. View "Kovach v. State" on Justia Law

The district court granted Father a divorce from Mother. The divorce decree granted Father primary physical and residential custody of the parties' two children, while Mother was granted "reasonable and liberal visitation." Three years later, Mother filed a motion to modify the custody arrangement. The district court determined that Mother failed to demonstrate that there had been a material and substantive change in circumstances since the last request for custody modification and denied the motion. The Supreme Court affirmed, holding (1) sufficient facts supported the district court's conclusion that Mother failed to demonstrate a material change in circumstances surrounding the custody and visitation order, and for that reason, the court was not required to engage in an analysis of whether a change in custody or visitation was in the best interests of the children; and (2) the Court declined to consider Mother's argument that the children's treating counselor's notes and written opinion were admissible into evidence at the motion hearing as business records under Wyo. R. Evid. 803(6) because that issue was raised for the first time on appeal. View "Willis v. Davis" on Justia Law

Wife filed a complaint for divorce from Husband. The district court granted Wife a divorce and distributed all of the property between Husband and Wife. Wife subsequently appealed the property distribution in the divorce decree, asserting that the district court abused its discretion when it divided the property contrary to the evidence presented at trial and when it failed to consider the financial condition in which the parties were left after the divorce. The Supreme Court affirmed and awarded Husband his costs and attorney's fees associated with this appeal, holding (1) Wife failed to comply with Wyo. R. App. P. 3.02(b) by failing to provide the Court with a transcript of the district court proceedings; (2) because the Court could not review the evidence, it could not find that the district court abused its discretion in how it divided the parties' property; and (3) because there was no transcript in the record, the Court could not certify that there was reasonable cause to bring this appeal. View "Golden v. Guion" on Justia Law

After an adjudicatory hearing in this abuse and neglect case, Appellant was found to have neglected her three children. Appellant appealed, arguing that she was denied fundamental due process rights because the trial court declined to grant a motion to dismiss or to strike witnesses after claimed discovery violations by the State and because the evidence was insufficient to support a finding of neglect. The Supreme Court affirmed, holding (1) the trial judge did not abuse his discretion in dealing with the claimed discovery violations; (2) Appellant received due process; and (3) the evidence was sufficient to support a finding of neglect. View "DL v. State, Dep't of Family Servs." on Justia Law

The Thornhocks filed an action against the Esterholdts and others seeking to quiet title to certain lands in Lincoln County. The district court granted summary judgment to the Thornocks as to some of the land but denied summary judgment as to a certain strip of property. After a bench trial, the district court quieted title in the disputed strip of land in the Esterholdts. The Supreme Court affirmed, holding (1) an appurtenant easement was not created by a deed that granted, in addition to tracts of fee title land, also that "right of way to be used in connection with said land"; and (2) an appurtenant easement was not created by a deed that granted a "right-of-way" described as the land now in question. View "Thornock v. Esterholdt" on Justia Law

Defendant was convicted of two counts of first degree sexual abuse of a minor and one count of second degree sexual abuse of a minor upon his three daughters. Defendant appealed. The Supreme Court affirmed, holding (1) the prosecutor did not commit misconduct when he questioned a witness about an exhibit that he did not intend to submit into evidence; (2) as to two of the victims, there was not a fatal variance between the charges in the information and the charges proven at trial, and the evidence was sufficient to support the convictions; and (3) the trial court did not abuse its discretion when it prohibited Defendant's expert witness from testifying about his opinion on what type of sexual abuse allegations were made in this case, as the proposed testimony fell outside the range of permissible opinion testimony. View "Craft v. State" on Justia Law

Appellant injured her neck and shoulder in a work-related accident. The Workers' Safety and Compensation Division approved Appellant's application for temporary total disability benefits but denied payments of two medical bills related to Appellant's lower back, concluding that the case was only left open for shoulder and neck injury. The office of administrative hearings (OAH) upheld the Division's denial of benefits. Appellant appealed. While on review in the district court, Appellant's counsel discovered documentation of a physical therapy session held approximately one month after Appellant's workplace accident that indicated she was experiencing pain in the middle of her back. Appellant unsuccessfully filed a motion to supplement the record with the physical therapy record. Appellant subsequently dismissed her appeal. Appellant then filed a Wyo. R. Civ. P. 60(b) motion for relief from final judgment based on the physical therapy record. The OAH denied the motion. The district court affirmed. The Supreme Court affirmed, holding (1) Appellant provided no evidence to support her claim that the failure to introduce the physical therapy record was caused by her trial counsel's mistake or inadvertence, and (2) Appellant failed to prove the significance of the medical record to her claim for benefits relating to her low back. View "Tegeler v. State ex rel. Workers' Safety & Comp. Div" on Justia Law

After a jury trial, Appellant was convicted of four counts of sexual abuse of a minor in the second degree. Appellant appealed, complaining that the prosecutor engaged in improper misconduct and that he was denied a fair trial as a result of the violation of his right against self-incrimination caused by the deficient assistance of counsel. The Supreme Court affirmed, holding (1) Appellant failed to demonstrate that the questions asked by the prosecutor were so harmful and prejudicial that any unfairness or injustice occurred; and (2) trial counsel did not render ineffective assistance for not objecting to a presentence investigation and for failing to advise Appellant that he need not submit to such an investigation. View "Leonard v. State" on Justia Law

In 2006, Teton County voters approved a Teton County Housing Authority (TCHA) sponsored ballot initiative enabling a specific purpose excise tax (SPET) to raise $5 million for TCHA's affordable housing program. In 2007, TCHA purchased a five-acre property on Cheney Lane. Later that year, Plaintiffs, residents of the Cheney Lane neighborhood, initiated a declaratory judgment action against TCHA, alleging violations of SPET limitations, breach of investment duties, and violations of Wyoming statutory limits on public financing. Two weeks after the district court heard arguments on the motion to dismiss, the Village Road Coalition (VRC), a nonprofit corporation consisting of residents of a neighborhood near the Cheney Lane property, filed a motion to intervene. The district court denied the motion. The court subsequently granted TCHA's motion to dismiss the complaint for lack of standing. The Supreme Court affirmed, holding (1) because VRC's interests and relief sought were duplicative of those presented by Plaintiffs, the district court did not err in denying the motion to intervene; and (2) the district court properly dismissed TCHA's action for lack of standing, as Plaintiffs failed to allege a tangible interest that had been harmed by the acquisition of the property. View "Village Road Coal. v. Teton County Hous. Auth." on Justia Law

In 2001, Plaintiff offered to purchase a commercial property. Defendant was the real estate agent who prepared the offer. The sellers accepted the offer to purchase and prepared a property disclosure statement in compliance with the contract requirement. Plaintiff became the sole owner of the property in 2004. Two years later, Plaintiff discovered three inches of water in the building basement that had leaked through the west wall of the foundation of the building. In 2012, Plaintiff filed a complaint against Defendant, alleging he was negligent in failing to provide the property disclosure statement. The district court dismissed the action on account of the two-year statute of limitations having expired. Plaintiff appealed, arguing that the district court erred in ruling that Defendant had no duty to disclose or provide the property disclosure statement. The Supreme Court dismissed the case due to Plaintiff's failure to challenge the statute of limitations ruling by the district court. The Court also noted that the district court acknowledged that Defendant owed Plaintiff a duty to deliver the disclosure statement. View "Ferrell v. Knighten" on Justia Law