Justia Wyoming Supreme Court Opinion Summaries

These consolidated appeals arose from a judgment on jury verdict in a case involving personal injuries suffered by Appellant Marcia Beckwith. Beckwith fell from a horse while on a trail ride operated by the Gros Ventre River Ranch in Grand Teton National Park. The jury found that Beckwith's injuries were the result of an inherent risk of horseback riding as defined by the Wyoming Recreation Safety Act, and she therefore recovered no damages for her injuries. In one appeal, Beckwith claimed the district court erred in failing to instruct the jury as she requested. In the other appeal, Beckwith claimed the district court erred in awarding costs to Appellees, the ranch and the ranch's owners, due to her indigence. The Supreme Court affirmed, holding (1) the district court properly instructed the jury as to Appellant's claims, and also provided an appropriate form of special verdict for the jury's use; and (2) the award of costs the district court made was not an abuse of discretion. View "Beckwith v. Weber" on Justia Law

In 2003, Shaw Construction obtained a line of credit from Rocky Mountain Hardware (RMH). Over the years, RMH supplied hardware for several jobs on which Shaw was the general contractor. In 2007, Shaw began work on a project for Snake River Sporting Club in which it acted as construction manager rather than general contractor. Although RMH was chosen as the hardware supplier, no separate contract was executed between RMH and either Shaw or Snake River. After none of the balance due was paid, RMH filed the instant action against Shaw, claiming Shaw was obligated to pay the outstanding balance and that RMH had a written contract with Shaw by virtue of the 2003 credit agreement. Shaw claimed Snake River was responsible for all payments to suppliers. The district court ordered Shaw to pay for the hardware furnished by RMH on the project as well as contractual interest and attorney fees. The Supreme Court affirmed, holding that the district court properly ruled the credit agreement applied in this case and, pursuant to its terms, Shaw was responsible for the principal balance due on the hardware contract, together with contractual interest and attorney fees. View "Shaw Constr., LLC v. Rocky Mountain Hardware, Inc." on Justia Law

Pursuant to a plea agreement, Christina Clark pled guilty to two counts of third degree sexual abuse of a minor. The district court sentenced her to two concurrent terms of six to ten years in prison. Clark appealed from the judgment and sentence, claiming her guilty pleas were not voluntary and she was entitled to a new sentencing hearing because the district court failed to mention probation in the written judgment and sentence in accordance with Wyo. R. Crim. P. 32. The Supreme Court affirmed but remanded for entry of an amended judgment, holding (1) Clark made a voluntary and informed choice to plead guilty; and (2) the district court in this case clearly considered probation before imposing a prison sentence. Remanded to the district court with directions to enter an amended sentence reflecting that the court considered probation in accordance with Rule 32. View "Clark v. State" on Justia Law

Appellant Chip Dave purchased a car on eBay. Before he took possession of the vehicle, the seller sold it to another buyer, Appellee Bill Valdez. Appellant filed a complaint against Appellee citing a number of causes of action, including replevin. Following Appellee's failure to respond to Appellant's second amended complaint, a default judgment was entered and Appellant was granted a writ of replevin ordering Appellee to relinquish possession of the vehicle. Appellant then appealed the district court's denial of an award of attorney fees, arguing that the American rule, requiring each party to pay his or her own attorney fees, was inapplicable. The Supreme Court affirmed, holding (1) the statutory exception to the American rule applies only where the legislature has made it explicit that attorney fees will be allowed; and (2) in this case, no exception to the American rule applied. View "Dave v. Valdez" on Justia Law

Dennis Poitra and two other assailants were involved in the armed robbery of a residence that ended in the killing of a seventy-six-year-old. A jury convicted Poitra of felony murder, aggravated burglary, and conspiracy to commit burglary. The Supreme Court affirmed, holding (1) the trial court did not err in denying Poitra's right to present the defense of involuntary intoxication and in refusing to instruct the jury on the defense of involuntary intoxication; (2) the trial court did not abuse its discretion in denying Poitra's motion to change venue and did not violate his right to a trial by a fair and impartial jury in doing so; and (3) the district court did not abuse its discretion in sentencing Poitra to life imprisonment without the possibility of parole. View "Poitra v. State " on Justia Law

John and Minerva Sutherland entered into a mining lease granting Meridian Granite Company the right to conduct mining operations on the Sutherlands' property. A dispute developed between the Sutherlands and Meridian regarding the Sutherlands' obligation to pay taxes relating to the mineral production. The dispute led to litigation. The district court granted Meridian's motion for summary judgment, ruling that the Sutherlands were obligated to pay the disputed taxes. The Supreme Court affirmed, holding that the district court did not err in allowing Meridian to deduct ad valorem and severance taxes from payments to the Sutherlands when such tax payments were not required by the State, as the Sutherlands and Meridian agreed in the mining lease that the Sutherlands would pay the taxes. View "Sutherland v. Meridian Granite Co." on Justia Law

Appellant Hailey Remmick was convicted of six counts of receiving stolen property and one count of conspiracy to commit larceny by a bailee. Remmick appealed, claiming that pre-charging delay deprived her of due process of law and that there was insufficient evidence to support the jury's verdict. The Supreme Court affirmed, holding (1) because there was no indication that the delay in bringing charges was motivated by an intentional effort to gain tactical advantage over Remmick or evidence that Remmick suffered any actual prejudice, the district court did not err in denying Remmick's motion to dismiss the charges; and (2) there was sufficient evidence to support Remmick's convictions on the charges of receiving stolen property and conspiracy to commit larceny by a bailee. View "Remmick v. State" on Justia Law

This case concerned a petition for the establishment of a private road filed by Merlin and Lori Zowada. In the first appeal, the Supreme Court remanded the case to the district court for further remand to the county board of county commissioners (the Commission) to make adequate findings of fact on specific issues. While the case was pending before the Court, the legislature amended Wyo. Stat. Ann. 24-9-101, which governs the procedure used when petitioning for the establishment of a private road. On remand, the Commission and its hearing officer chose to apply the statute as amended in 2008 and 2009, although the case had originally proceeded under the statute as it existed in 2005. Mullinax filed a petition for writ of review, arguing that the 2005 version of the statute should apply to the proceedings. The district court denied the petition. The Supreme Court reversed, holding that the hearing officer's decision to apply the statute as it existed in 2009 was in error, as, while the amendments to the statute were procedural in nature, the general rule against retroactive application of the amendment applied. Remanded. View "Mullinax Concrete Serv. v. Zowada" on Justia Law

Pursuant to a plea agreement, David Mercer pleaded no contest to three felony counts of sexual abuse of a minor. After he was sentenced, Mercer appealed, asserting that the State breached its plea agreement at sentencing when it misstated facts and argued for a harsh sentence based on Mercer's alleged failure to accept personal responsibility. The Supreme Court affirmed, holding that Mercer failed to establish that the State breached the plea agreement where (1) a misstatement made by the prosecutor did not prejudice Mercer or violate any clear and unequivocal rule of law; and (2) the prosecutor properly recommended that Mercer should receive the maximum possible sentence based on Mercer's attempt to minimize his behavior. View "Mercer v. State" on Justia Law

Victor Jackson pled guilty to one count of third degree sexual assault in exchange for the state's agreement to request probation. The district court placed him on supervised probation for five years. Six months later, the State filed a petition to revoke his probation. A year later, Jackson filed a motion to withdraw his guilty plea, asserting that the victim of the assault had identified someone else as the perpetrator. The district court denied the motion and entered an order revoking probation. The court then imposed a sentence of four to five years. The Supreme Court affirmed the district court's denial of the motion to withdraw, holding that there was nothing in the record indicating that the district court could not reasonably have concluded as it did or that some facet of its ruling was arbitrary or capricious. View "Jackson v. State" on Justia Law