Justia Wyoming Supreme Court Opinion Summaries

Catherine Morris submitted a worker's compensation claim for permanent total disability (PTD) benefits, and the Wyoming Workers' Safety and Compensation Division denied her claim. The Wyoming Medical Commission upheld the Division's denial of benefits. The district court affirmed. The Supreme Court affirmed, holding (1) the Commission did not abuse its discretion in admitting a psychological report produced after the discovery cutoff; and (2) the Commission abused its discretion in limiting the scope of Morris' testimony to matters not discussed in the discovery deposition taken by the Division, but Morris did not object below to that limitation and thus waived her right to appeal that issue. View "Morris v. State ex rel. Workers' Safety & Comp. Div." on Justia Law

Following a jury trial, Timothy Kramer was convicted of attempted first-degree murder. The Supreme Court affirmed, holding (1) the trial court did not plainly err in instructing the jury on the elements of first-degree murder; (2) Kramer's trial attorneys were not ineffective by not objecting to the jury instructions, and counsel's investigation into the timeline of events was sufficient; and (3) the trial court did not err or violate Kramer's confrontation right when it allowed one of the main witnesses in the trial to testify via video conference, as, under the circumstances, presentation of this testimony in that manner was necessary to further an important public policy, and the reliability of the testimony was otherwise assured. View "Kramer v. State" on Justia Law

Appellant was the mother of three children who were taken into protective custody and placed into foster care. The Department of Family Services (DFS) later filed a petition to terminate Appellant's parental rights. Because Appellant did not timely file an answer to the petition, default was entered against Appellant. After a default hearing, the district court issued an order terminating Appellant's parental rights. The Supreme Court affirmed, holding (1) Appellant, who failed to timely answer the petition to terminate parental rights, was permitted to challenge the sufficiency of the evidence in this appeal; and (2) there was sufficient evidence presented in the default hearing and in the complaint to constitute clear and convincing evidence to support the termination of Appellant's parental rights. View "DMM v. State" on Justia Law

Defendant Christopher Counts was convicted of aggravated burglary and kidnapping. On appeal, the Supreme Court affirmed, holding (1) any error by the district court in admitting redacted documents and recordings into evidence was harmless; (2) the district court erred by limiting Defendant's cross-examination of the victim, but the error was harmless; (3) the district court did not abuse its discretion in denying a motion for a bill of particulars; (4) the district court properly instructed the jury; (5) the verdict was consistent; and (6) there was sufficient evidence to support the verdict on the charges of kidnapping and aggravated burglary. View "Counts v. State" on Justia Law

Chrstine Nodine, whose husband was killed by an avalanche on a ski run at Jackson Hole Mountain Resort (JHMR), appealed the district court's summary judgment order dismissing her wrongful death action. The court dismissed the action pursuant to Estate of Johnson because Nodine, although duly appointed as personal representative of her husband's estate in her home state of Texas, had not been appointed personal representative by the Wyoming state district court upon the filing of her wrongful death action and before the two-year period for filing the wrongful death action expired. The Supreme Court reversed, holding (1) the cause of action in this matter accrued before the publication of Johnson; and (2) the Court's decision in Johnson was intended to have prospective operation only and did not apply retroactively to strip Nodine of her status as a properly appointed personal representative in her wrongful death action against JHMR. View "Nodine v. Jackson Hole Mountain Resort Corp." on Justia Law

Alfred Baldes, a certified nursing assistant, was convicted of two counts of third-degree sexual assault after giving a young man who suffered from muscular dystrophy a sponge bath. The Supreme Court affirmed, holding (1) the evidence presented at trial was sufficient to sustain Baldes' conviction, and specifically, there was sufficient evidence for a reasonable juror to conclude that Baldes was in a position of authority and that sexual contact occurred, respectively; and (2) the trial court did not err when, following a Gleason analysis, it allowed the introduction of Wyo. R. Evid. 404(b) evidence, specifically the testimony of another client of Baldes'. View "Baldes v. State" on Justia Law

Soon after Yale Preston was employed by Pennaco Energy, a wholly-owned subsidiary of Marathon Oil Company (collectively referred to as Marathon), Preston signed an employee agreement with a disclosure and assignment of intellectual property clause. The present dispute centered around allegations of patent infringement and questions of ownership of two patents that covered a baffle system that Preston invented. The district court found that Preston was the sole inventor of the patents and that the employee agreement was a valid contract, pursuant to which Preston was required to assign his ownership interest in the patents to Marathon. At issue on appeal was the validity of the assignment of intellectual property rights given to Marathon without an additional consideration other than continued at-will employment. The Supreme Court accepted certification and held that continuing the employment of an existing at-will employee constitutes adequate consideration to support an agreement containing an intellectual property-assignment provision. View "Preston v. Marathon Oil Co." on Justia Law

After being separately cited and arrested for driving while under the influence of alcohol (DWUI), Ricky Miller and Christopher Gonzalez (Petitioners) petitioned the district court for review of agency inaction by the Wyoming Department of Health (WDOH). Miller and Gonzalez requested that the district court require the WDOH to retroactively decertify the chemical test operators who had performed chemical tests of Petitioners' breath to determine the quantity of alcohol in their respective bodies. The district court dismissed the petition on the grounds that Petitioners lacked standing to bring the action and that the matter was not ripe for review. The Supreme Court affirmed, holding that Petitioners did not satisfy the three elements of standing as set forth in Lujan v. Defenders of Wildlife, and therefore, the district court did not err in dismissing Petitioners' petition for review for lack of standing. View "Miller v. Dep't of Health" on Justia Law

Earl and Nawana Wallace (the Senior Wallaces) borrowed $15,789 from Pinnacle Bank - Wyoming to finance a vehicle the Senior Wallaces purchased for their son and his wife (the Junior Wallaces). The collateral for the loan was the vehicle the Senior Wallaces bought for and titled in the Junior Wallaces' names. To that end, the Junior Wallaces signed a third party security agreement pledging the vehicle as collateral. The Junior Wallaces subsequently filed a bankruptcy petition. The bankruptcy trustees eventually sold the vehicle to benefit the bankruptcy estate. The Senior Wallaces thereafter stopped making payments on the loan. Pinnacle then filed a complaint seeking damages in the amount of the principal due on the note. The district court granted Pinnacle's motion for summary judgment. The Supreme Court affirmed, holding that none of the Senior Wallaces' asserted defenses excused them from meeting their loan obligation. View "Wallace v. Pinnacle Bank - Wyo." on Justia Law

Dan Artery was attacked by three Boston terriers that were under the care of Frank Jones and Amy Bates. Artery brought an action against Jones and Bates for injures he sustained during the attack. During trial, Jones admitted one hundred percent liability for the injuries, and the district court dismissed Bates as a defendant. The jury then awarded Artery damages in the amount of $13,059. The district court thereafter ordered Jones to pay Artery's costs. Jones appealed a portion of the awarded costs. The Supreme Court affirmed in part and reversed in part, holding that the district court abused its discretion in awarded costs for witness subpoena service fees for an earlier vacated trial because the original trial date was vacated by the district court on its own motion. Remanded. View "Jones v. Artery" on Justia Law