Justia Wyoming Supreme Court Opinion Summaries

Sheridan Fire Fighters Local No. 276 filed suit against the City of Sheridan alleging that the City breached the parties' collective bargaining agreement when it failed to provide pay raises to five firefighters who had qualified for a "step increase" in salary. The City responded that the raises were not required and that, under the terms of the agreement, the City retained discretion in the award of pay raises. The district court granted summary judgment for the City. The Supreme Court reversed and remanded for entry of summary judgment in favor of Local 276, holding (1) the agreement was ambiguous about whether step increases in salary were mandatory or left to the City's discretion; and (2) because Local 276 presented evidence in support of its summary judgment motion consistent with the union's interpretation that the agreement required the City to give step increases to all eligible firefighters, and the City offered no evidence to the contrary, there were no genuine issues of material fact, and Local 276 showed it was entitled to judgment in its favor. View "Sheridan Fire Fighters Local No. 276 v. City of Sheridan" on Justia Law

Appellant pled guilty to unlawful use of a credit card (a misdemeanor) and forgery (a felony). The district court denied Appellant's motions to modify his sentence, correct an illegal sentence, and reduce his sentence. Appellant unsuccessfully filed a motion for postconviction relief and another motion for a reduction of his sentence. Finally, Appellant filed a motion to correct an illegal sentence based on the same allegations he raised in the petition for postconviction relief, namely, that he was denied a direct appeal, that he received ineffective assistance of counsel, and that the prosecutor engaged in misconduct. The district court denied the motion. Appellant appealed, arguing that his sentence was illegal because he was not advised that his guilty pleas may result in the disqualification of his right to possess firearms pursuant to federal law. The Supreme Court affirmed, holding that the Court could not consider Appellant's argument because it was being raised for the first time on appeal, and further, even if the issue had been raised before the district court, it would have been barred by the doctrine of res judicata. View "Lunden v. State" on Justia Law

Pursuant to multiple search warrants the Cheyenne Police Department seized property from Appellant's residence in 1999. Subsequent to that search, Appellant was arrested and convicted on six counts of sexual assault. For the next several years, Appellant litigated issues surrounding the seized property. In 2011, Appellant filed a 42 U.S.C. 1983 complaint for damages arising out of the property confiscated from his home. The district court dismissed Appellant's claim as time barred. The Supreme Court affirmed, holding (1) the district court correctly dismissed the complaint as time barred; and (2) the issues relating to this property are concluded, and in order to ensure that finality, the Court directed that Appellant be prohibited from filing any further litigation relating to the subject matter of this case. View "DeLoge v. Homar" on Justia Law

Greencore Pipeline Company filed an action seeking to condemn easements across property owned by Barlow Ranch for a pipeline to transport carbon dioxide. The parties reached an agreement on the terms of possession and scope of the easements but disputed the amount that would justly compensate Barlow for the partial taking of its property. During trial, Barlow presented evidence of prices paid for other comparable pipeline easements to show the air market value of Greencore's easement. The district court awarded compensation based upon the average of the amounts Greencore had paid other landowners for easements for its carbon dioxide pipeline. Both parties appealed. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) properly ruled that it could consider evidence of comparable easements in determining just compensation; (2) erred in concluding Barlow's proffered easements were not the result of arms' length transactions or sufficiently comparable, while the other Greencore easements were; (3) erred by concluding annual payments were not allowed under Wyoming law; and (4) correctly ruled that the issue of whether Greencore may abandon the pipeline in place was not properly before the Court. View "Barlow Ranch, LP v. Greencore Pipeline Co., LLC" on Justia Law

The Wyoming Oil and Gas Conservation Commission approved Cimarex Energy Company's plan to reinject waste carbon dioxide and hydrogen sulfide into a producing natural gas formation in southwest Wyoming over the objection of Exxon Mobil Corporation. Exxon appealed. The district court affirmed the Commission's decision. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the Commission properly denied Exxon's petition for a rehearing; but (2) the Commission failed to provide sufficient findings of fact as to whether Cimarex's plan to reinject carbon dioxide and hydrogen sulfide would result in waste of natural gas and improperly interfere with Exxon's correlative rights. Remanded to the Commission to make appropriate findings of both basic and ultimate facts. View "Exxon Mobil Corp. v. Wyo. Oil & Gas Conservation Comm'n" on Justia Law

Appellants purchased Mom's Malt Shop (Mom's) from Meisinger Investments, which was subsequently dissolved. Six years later, Appellants filed a complaint against Meisinger Investments and one of its owners, Richard Meisinger (Appellees) for breach of contract and breach of the covenant of good faith, alleging that Appellees misrepresented the inventory of the equipment of Mom's, among other things. Appellees filed a motion to dismiss, asserting, inter alia, that the sale of Mom's was between Appellants and Meisinger Investments and that Appellants had not made any allegations that would justify piercing the corporate veil to hold Richard personally responsible. The district court dismissed Appellants' complaint, finding that the complaint was insufficient to survive a motion for summary judgment. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the district court improperly converted Appellees' motion to dismiss to a motion for summary judgment; (2) the district court correctly found that Appellants failed to present any allegations that would put Appellees on notice that Appellants were seeking to pierce the corporate veil in an attempt to hold Richard personally liable for the claims against Meisinger Investments; and (3) Appellants did present a proper claim against Meisinger Investments. View "Ridgerunner, LLC v. Meisinger" on Justia Law

Defendant conditionally pleaded guilty to possession with intent to deliver marijuana. On appeal, Defendant challenged the district court's denial of his motion to suppress evidence discovered during a search of his vehicle. Defendant argued that because the drug dog sniff was inconclusive, the subsequent search of his vehicle was illegal. The Supreme Court affirmed, holding that the totality of the circumstances was sufficient to find probable clause, as additional facts beyond the dog search were used by the district court to determine that probable cause existed, and an officer of reasonable prudence would have been warranted in the belief that controlled substances would be found in Defendant's vehicle. View "Phippen v. State" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree and sexual abuse of a minor in the first degree. Defendant appealed the district court's denial of a continuance motion and the court's admission of uncharged misconduct evidence of his prior conviction for sexual assault of a minor. The Supreme Court affirmed, holding that the district court did not abuse its discretion (1) when it denied Defendant's motion for a continuance of the trial due to a missing witness and in concluding that the unavailable testimony lacked materiality; and (2) in admitting into evidence testimony of the victim that resulted in a prior conviction of Defendant for sexual assault. View "Huckfeldt v. State" on Justia Law

Appellant, who worked for the Wyoming Department of Corrections, sustained significant injuries during a vehicle rollover while driving to pick up a prisoner. The Workers' Safety and Compensation Division awarded Appellant a partial impairment award, after which Appellant applied for permanent total disability (PTD) benefits. The Division denied her application, finding that she did not meet the statutory definition of PTD. The Medical Commission concluded that Appellant did not meet her burden of proving that she was entitled to PTD benefits. The district court affirmed. The Supreme Court reversed, holding that Appellant presented a prima facie case showing that she was unemployable in her community due to her injuries, and the Division failed to rebut this showing by demonstrating that there was in fact gainful employment available to her within a reasonable geographic area. Remanded. View "Stallman v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Father and Mother divorced in 2007. In the litigation that followed the divorce, the district court granted Mother's motion to modify the visitation schedule, denied Father's request to present expert testimony, denied Father's claims for child support abatement, denied Father's petition to modify child support, partially reimbursed Father's day-care expenses, and awarded attorney's fees to Mother. The Supreme Court reversed in part, holding that the district court abused its discretion (1) in finding father was not entitled to an abatement in child support; (2) by only partially reimbursing Father for day-care expenses because the divorce decree did not require Father to pay any day-care expenses while he was paying child support; and (3) in awarding attorney's fees against Father because Mother presented insufficient evidence indicating that the fees requested were reasonable. The Court otherwise affirmed. Remanded. View "Jensen v. Milatzo-Jensen" on Justia Law