Justia Wyoming Supreme Court Opinion Summaries

Black Diamond Energy Partners (BDE Partners) were Nevada limited partnerships which owned interests in coal bed methane wells located in Wyoming. Black Diamond Energy, Inc. (BDE Inc.) was a Wyoming corporation and the managing general partner of several of the BDE Partners. Black Diamond Energy, Inc. of Delaware (BDE Del) was a Delaware corporation and the managing general partner of two of the BDE Partners. BDE Inc. and BDE Del were wholly owned subsidiaries of Koval Resources, LLC, a Nevada limited liability company. Koval entered in a loan agreement in Pennsylvania with S&T Bank, a regional state bank with offices only in Pennsylvania. Koval ultimately defaulted on the loan. BDE Partners filed a complaint in Wyoming against S&T alleging negligence, breach of fiduciary duty, breach of the implied covenant of good faith and fair dealing, and other claims. The district court dismissed the complaint for lack of personal jurisdiction. The Supreme Court reversed, holding that BDE Partners presented sufficient undisputed evidence that S&T's activities in Wyoming were such that, as a matter of law, Wyoming courts had personal jurisdiction to decide their claims. View "Black Diamond Energy Partners Ltd. v. S&T Bank" on Justia Law

After entering a conditional plea to one count of felony child abuse, Roman Vance reserved his right to challenge the denial of his motion to dismiss, which was premised on grounds of constitutional speedy trial. On appeal, Vance claimed that a six and one-half year delay between charging and arrest raised a presumption of prejudice that the State did not persuasively rebut. The Supreme Court agreed and reversed, holding that the district court erred in denying Vance's motion to dismiss based upon a violation of his constitutional speedy trial right, as the court overlooked the question of presumptive prejudice and because no evidence was offered by the prosecution to rebut the presumption of prejudice afforded to Vance. View "Vance v. State" on Justia Law

Appellant in this case attempted to challenge an agency decision denying her claim for unemployment benefits. Appellant filed a timely petition for review of agency action pursuant to Wyo. R. App. P. 12 (Rule 12). The district court dismissed the petition due to procedural deficiencies. Appellant subsequently filed a motion for reconsideration based on Wyo. R. Civ. P. 60 (Rule 60). The district court denied the motion. Appellant then appealed the order denying her motion for reconsideration. At issue on appeal was whether, when a district court enters a final judgment in a Rule 12 agency appeal, a party can file a Rule 60 motion to set aside the court's judgment. The Supreme Court dismissed Appellant's appeal, holding that a Rule 60 motion is not an avenue available to mount a challenge to a district court's final decision in an agency appeal. View "Nicholson v. Dep't of Employment" on Justia Law

Bill Kuhl brought wrongful termination claims against his former employer, Wells Fargo Bank, asserting claims for breach of an express contract of employment, breach of an implied contract of employment, promissory estoppel, and tortious breach of the implied covenant of good faith and fair dealing. After the parties engaged in discovery, Wells Fargo moved for summary judgment. Kuhl resisted that motion. After a hearing, the district court granted summary judgment in favor of Wells Fargo. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of Wells Fargo on any of Kuhl's claims. View "Kuhl v. Wells Fargo Bank, N.A" on Justia Law

Jackman Construction, Inc. was awarded a contract to improve the Town of Baggs' water treatment plant. After the project suffered significant delays, payments were submitted and accepted, and a dispute ensued as to whether or not the last payment constituted "final payment." Jackman filed a governmental claim as well as a complaint for breach of contract, seeking damages from the Town. The Town filed a motion for summary judgment, which the district court granted. The Supreme Court affirmed, holding that under the clear and unambiguous terms of the contract, Jackman agreed to waive all claims by accepting "final payment," which it did. View "Jackman Constr., Inc. v. Town of Baggs " on Justia Law

KM Upstream, LLC and Newpoint, Inc. entered into a contract whereby Newport would construct for KM's amine plant. Newpoint subcontracted with Elkorn Construction, Inc. to build the foundation and perform other work. Elkhorn subsequently filed a lien statement with the county clerk. Elkhorn later filed a complaint against KM for, inter alia, foreclosure of the lien as a mechanic's lien. Newpoint was later added as a defendant. The district court granted summary judgment to Elkhorn to allow foreclosure on the mechanic's lien. The Supreme Court (1) affirmed the grant of summary judgment; but (2) reversed and remanded the district court's determination that $181,369 of Elkhorn's lien claim was disputed and its subsequent order subtracting that amount from Elkhorn's judgment. View "KM Upstream, LLC v. Elkhorn Constr., Inc." on Justia Law

This was an appeal from a forfeiture order entered by the district court against a total of $116,584 and certain items of personal property. The cash and personal property were seized from several individuals because of their alleged use in violation of the Wyoming Controlled Substances Act. Appellants Joseph Libretti and Frank Hohlios claimed $7,209 of the cash seized and appealed the forfeiture order, contending that the district court erred in holding an evidentiary hearing without ruling on their motions to dismiss or for a more definite statement, and in denying them the opportunity to file answers, conduct discovery, file summary judgment motions, or avail themselves of the right to a jury trial. The Supreme Court affirmed, holding that the district court acted in accordance with the Wyoming Rules of Civil Procedure in ruling on the State's forfeiture complaint and did not deny the rights of Appellants to file answers, conduct discovery, file summary judgment motions, or otherwise fully participate in the proceedings. View "Libretti v. State" on Justia Law

Father resisted a petition by Stepfather to adopt Father's three youngest children. The district court approved the adoption over Father's objections. The Supreme Court affirmed, holding that the district court did not err in (1) calculating that arrearages in Father's child support payments; (2) failing to give Father credit for social security payments made directly to Mother as child support; (3) finding Stepfather fit and competent to adopt the children; (4) failing to consider information contained in Father's answer to the petition for adoption, in Father's proposed findings of fact following the hearing in this matter, and in a letter sent to the court by Stepfather's attorney after the hearing; and (5) denying Father's motions for visitation with the children. View "SL v. CAD" on Justia Law

After the owner of a construction project defaulted on its obligations to various creditors, mortgage holder Pinnacle Bank foreclosed on the real property securing its mortgage. Junior mortgage holder American National Bank (ANB) and construction lienholder Michael's Construction, Inc. (Michael's) both sought payment from the surplus funds resulting from the foreclosure proceeding. The district court declared that ANB's mortgage was superior to Michael's lien, but denied ANB's request for contractual interest from the date of foreclosure through the date of final judgment. The Supreme Court (1) affirmed the district court's order regarding the priority of liens; but (2) reversed the order regarding interest, holding that the district court did not have the discretion to limit ANB's recovery by denying it interest at the contractual rate from the time of foreclosure through final judgment. Remanded to determine the amount of interest due ANB under the promissory note for that time period. View "Michael's Constr., Inc. v. Am. Nat'l Bank " on Justia Law

After a jury trial, Appellant Francis Guerrero was convicted of felony larceny. The district court sentenced Appellant to three to five years of imprisonment. Appellant appealed, claiming the district court erroneously instructed the jury on the elements of larceny and that the evidence presented at trial was insufficient to support his conviction. The Supreme Court agreed with Appellant's second claim and reversed, holding that the evidence was insufficient to show that Appellant's activities constituted a taking, one of the elements of larceny, as opposed to a conversion. Consequently, the Court found that Appellant was entitled to an acquittal on the charge of felony larceny. View "Guerrero v. State" on Justia Law