Justia Wyoming Supreme Court Opinion Summaries

These consolidated appeals stemmed from the Redland family's dispute over ranch property and operations. Two of the appeals related to real property that some of the Redland children claimed their father, Robert Redland, agreed to place in a family trust. The district court granted Robert partial summary judgment, holding that the claims were barred by the statute of limitations and statute of frauds. A bench trial was held on the remaining issues. The trial court ruled against Robert on his two sons' unjust enrichment claims for improvements they had made to the disputed trust properties and also ruled against Robert on his counterclaim against another child and his wife for a partnership interest in their cattle operation. In the remaining appeal, Robert appealed the trial court's rulings on the unjust enrichment and partnership claims. The Supreme Court (1) reversed the grant of summary judgment, holding that disputed issues of material fact existed on the questions of whether the Redland children's property claims were barred by the state of limitations or statute of frauds; and (2) affirmed the district court's ruling on the unjust enrichment claims and the partnership claims. Remanded. View "Redland v. Redland" on Justia Law

Appellant was injured in an accident that occurred during the course of her employment. After receiving a permanent partial impairment award from the Wyoming Worker's Compensation Division, Appellant sought permanent partial disability benefits. The Division denied Appellant's application, stating that she had not complied with the statutory work search requirements. After a contested case hearing, the Office of Administrative Hearings granted summary judgment for the Division, concluding that Appellant had not timely submitted documentation showing she had sought work. The district court affirmed. The Supreme Court reversed, holding (1) Appellant's work search submission was timely; and (2) Appellant was entitled to a hearing and the opportunity to present evidence showing that she actively sought work. View "Stallman v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

After being arrested for driving while under the influence, Appellant submitted a request for contested case hearing before the Office of Administrative Hearings (OAH) asking the OAH to rule that the procedure used by the arresting officer to conduct the chemical breath test upon which his arrest was based did not comply with Wyo. Stat. Ann. 31-6-105(a) and, therefore, the proposed suspension of his driver's license must be vacated. The OAH hearing examiner upheld the suspension. The district court affirmed. The Supreme Court affirmed, holding (1) it was proper for OAH to apply a presumption that the underlying chemical test result was valid; and (2) Appellant did not present any evidence at the administrative hearing to rebut the presumption that the breath test results were accurate and failed to meet the requirements of Wyo. R. App. P. 12.08 that would allow the Supreme Court to order the additional evidence to be taken before the agency. View "Romsa v. State ex rel. Wyo. Dep't of Transp." on Justia Law

Defendant was convicted on six felony charges involving sexual assault. The district court subsequently sentenced him to consecutive prison sentences totaling thirty to fifty years. The Supreme Court affirmed. Defendant subsequently filed motions for sentence reduction, one through counsel and one pro se. In the first motion, Defendant asserted sentence reduction was appropriate based upon his rehabilitation efforts. In his second motion, he asserted reduction was also appropriate because he was going blind in both eyes and his condition could be reversed only if he was able to seek outside medical attention. The district court denied both motions. Defendant appealed, claiming the district court erred when it denied motions without considering his change of circumstances. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant's motions for sentence reduction. View "Boucher v. State" on Justia Law

The Wyoming Workers' Safety and Compensation Division issued a final determination awarding Appellant a two percent permanent partial impairment benefit after Appellant was injured in a work-related accident. After a hearing, the Medical Commission upheld the Division's final determination. The district court's issued an order affirming the Medical Commission's decision. The Supreme Court affirmed, holding (1) in light of expert opinions, the criteria set forth in the AMA Guides, Appellant's medical records, and Appellant's symptoms at the time of the hearing, the Medical Commission's findings were supported by substantial evidence; and (2) even if the Court found that the Medical Commission's credibility findings were not supported by the record, substantial evidence would remain to support the Commission's decision. View "Willey v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Defendant entered an Alford plea to three counts of first degree sexual abuse of a minor and one count of third degree sexual abuse of a minor. The Alford plea allowed Defendant to enter a guilty plea without allocuting or otherwise admitting his participation in the crimes. During Defendant's sentencing hearing, the district court cited to a number of factors that influenced the court's sentencing decision and then commented on Defendant's flippancy and lack of remorse before announcing its decision. Defendant challenged the sentence, contending that the district court violated his constitutional right against self incrimination by using his silence as evidence of a lack of remorse. The Supreme Court affirmed, holding that Defendant did not establish that the district court inferred a lack of remorse based on his silence, and therefore, the question of whether such an inference would infringe on a Defendant's right against self incrimination did not need to be addressed. View "Joreski v. State" on Justia Law

Petitioner was injured in an accident while driving his motorcycle to work. He filed a claim for worker's compensation benefits asserting that his injuries were covered because he sustained them while traveling to work and his employer reimbursed him for travel expenses. The Wyoming Worker's Compensation Division denied his claim. After a hearing, the Office of Administrative Hearings (OAH) also denied his claim. The district court affirmed the denial. The Supreme Court affirmed, holding that the OAH's conclusion that Petitioner failed to meet his burden of proving he was reimbursed for travel expenses was not contrary to the overwhelming weight of the evidence. View "Bilyeau v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

After Swan Ranch was annexed by the City of Cheyenne in 2009, Appellants, neighbors to the land being annexed, filed a declaratory judgment action against the City alleging that the annexation was invalid under Wyo. Stat. Ann. 15-1-402(a). Ultimately, the district court granted the City's responding summary judgment argument on two claims and conducted trial on the third and final claim. Following trial, the district court found the annexation was proper. The Supreme Court affirmed, holding that the district court's decision upholding the Swan Ranch annexation was not clearly erroneous, as "the degree of contact, the location, and the character of the annexed parcel" were sufficient to satisfy the statutory requirements for annexation under section 15-1-402. View "Hough v. City of Cheyenne" on Justia Law

After a hearing, the district court entered an order stating that Appellant concealed, embezzled, conveyed away and/or disposed of monies and other property of John Hibsman, Jr.'s estate and finding prima facie evidence of the right of the estate's personal representative to recover an amount "not less than $137,566." At issue on appeal was whether the Supreme Court had jurisdiction to hear Appellant's appeal. The Court dismissed the appeal, determining it lacked jurisdiction to hear the appeal because (1) the order from which Appellant took his appeal was made in a "special proceeding" as contemplated by Wyo. R. App. P. 1.05; but (2) no substantial right of Appellant's was affected by the court's decision, as the proceeding appealed here merely determined a prima facie case that the personal representative could initiate litigation to determine if there was a wrongful taking of at least that amount of money. View "Hibsman v. Mullen" on Justia Law

This case arose out of a home construction contract between the contractors, Big-D Signature Corporation and two LLCs. Morris Sterrett was the owner of the property on which the home was built. Big-D filed suit against the LLCs and Sterrett, alleging breach of contract and unjust enrichment. The LLCs and Sterrett counterclaimed, alleging breach of contract. The district court entered a partial summary adjudication that was later partially vacated. A jury trial then commenced, but a mistrial was declared. A partial summary judgment order followed. The remaining issues were disposed of by the district court under a sua sponte dismissal with prejudice. Both sides appealed. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err in granting partial summary judgment for Plaintiff; (2) the court did not err in finding that Sterrett was individually liable; (3) the court erred in dismissing the issue of whether Big-D could obtain relief under some of the prime contract change orders (PCCOs); (4) the court erred in finding some of the items in the PCCOs were consequential damages barred by the contract; and (5) the court correctly dismissed the damages claims of the LLCs and Sterrett. View "Big-D Signature Corp. v. Sterrett Props., LLC " on Justia Law