Justia Wyoming Supreme Court Opinion Summaries

Appellant Jimmy Dean Smallfoot entered a conditional guilty plea to a charge of possession with intent to deliver a controlled substance. Smallfoot reserved the right to appeal the district court's denial of his motion to suppress the marijuana discovered inside his residence. On appeal, Smallfoot claimed the drug evidence should have been suppressed because it was the fruit of a constitutionally infirm warrantless entry into his home. The Supreme Court affirmed the district court's suppression ruling, holding that the court correctly determined that the officers' warrantless entry into Smallfoot's residence pursuant to the consent of another alleged resident of the home was constitutionally permissible. View "Smallfoot v. State" on Justia Law

Appellant Michael Beall received preauthorization from the Wyoming Workers' Safety and Compensation Division for an orchiectomy, a procedure to remove his left testicle, which he claimed was related to a workplace injury. Beall's employer, Sky Blue Enterprises, objected to the preauthorization and the matter was referred to the Medical Commission Hearing Panel for a contested case hearing. Beall elected to undergo the surgery prior to the scheduled hearing. The Commission denied Beall's claim for reimbursement of medical expenses on the basis that the surgery was not reasonable or necessary medical care resulting from his workplace injury. The district court affirmed. The Supreme Court affirmed, holding (1) the burden of proving that the orchiectomy was reasonable and necessary medical care as related to Beall's alleged workplace injury rested with Beall; and (2) substantial evidence supported the Commission's determination that Beall failed to meet this burden. View "Beall v. Sky Blue Enters., Inc." on Justia Law

Following a jury trial, Appellant Lawrence Silva was convicted for aggravated burglary and attempt to commit kidnapping. The district court sentenced Appellant to imprisonment for twelve to fifteen years on each count to be served concurrent. The Supreme Court affirmed the convictions and sentences, holding (1) the district court did not err by preventing Appellant from introducing certain evidence of the victim's previous sexual conduct, as the evidence was irrelevant to Appellant's defense; and (2) the district court properly declined to instruct the jury on the offense of false imprisonment as a lesser-included offense of kidnapping because the lesser-included offense required an element not required for the higher felony offense. View "Silva v. State" on Justia Law

Gary James was convicted of two counts of aggravated assault and battery and two counts of driving under the influence with serious bodily injury. The district court imposed four consecutive terms of eight to ten years of incarceration. James appealed, contending that the convictions should have merged to two convictions for sentencing purposes because the consecutive sentences violated his constitutional right against multiple punishments for the same offense. The Supreme Court affirmed, holding that because James committed two separate and distinct criminal acts against each of two victims, the district court appropriately imposed consecutive sentences for those separate offenses. View "James v. State" on Justia Law

Majorie Bedessem, as trustee of her revocable trust, filed a complaint against David and Susan Cunningham, seeking enforcement of an easement across the Cunningham property to access the Bedessem property. Bedessem claimed an implied access easement or, in the alternative, access pursuant to the restrictive covenants applicable to both properties. The district court granting Cunninghams' summary judgment motion after finding no evidence of an implied easement and that the restrictive covenants authorized only the Architectural Control Committee to sue for enforcement of the covenants. The Supreme Court affirmed, holding that the district court did not err when it ruled that Bedessem did not have standing to enforce a restrictive covenant against Cunninghams, as the covenants granted the Architectural Control Committee the sole right to enforce the covenants. View "Bedessem v. Cunningham " on Justia Law

Appellant received a sentence of twenty to twenty-two years imprisonment for a crime punishable by a term of twenty years to life. More than four years after starting his sentence, Appellant filed a motion to correct an illegal sentence, alleging that his sentenced violated Wyo. Stat. Ann. 7-13-201 because the minimum term was greater than ninety percent of the maximum term. Rather than decrease the minimum term below the statutory minimum, the district court increased the maximum term from 265 months to 267 months. Appellant appealed, arguing that increasing his sentence after he had begun to serve that sentence violated double jeopardy. The Supreme Court affirmed, holding (1) Appellant's original sentence was illegal because it violated the statutory requirement that a minimum term may not be more than ninety percent of the maximum term; (2) the district court correctly increased the maximum term; but (3) the corrected sentence should have reflected the appropriate credit for the time appellant had served. Remanded. View "Moronese v. State" on Justia Law

Brady Michaels was arrested for driving while under the influence of alcohol. The Department of Transportation (the State) notified him that it was suspending his driver's license for ninety days. The Office of administrative Hearings (OAH) upheld the suspension. The district court affirmed. The Supreme Court affirmed the district court's order upholding the license suspension, holding (1) the OAH's ruling that Wyo. Stat. Ann. 31-5-233(b) (the statute) does not distinguish between alcohol concentration caused by consuming alcoholic beverages and alcohol concentration caused by some other factor was incorrect, as the statute was intended to apply when a person drives or is in actual control of a motor vehicle after consuming alcohol beyond the legal limit or to a degree rendering him incapable of safely driving; but (2) the State met its burden of proving that probable cause existed at the time of the arrest to believe that Michaels had violated the statute. View "Michaels v. State ex rel. Dep't of Transp. " on Justia Law

Jimmie McMasters was working as an HVAC journeyman when he fell from a beam to a concrete floor and suffered an injury. McMasters applied for permanent total disability benefits claiming a total disability. The Wyoming Workers' Safety and Compensation Division denied the application. The Division did not dispute that McMasters could not return to work but instead contended that McMasters' failure to obtain alternative employment was due to a preexisting psychological condition and a poor effort to find work. The Medical Commission agreed and upheld the denial of benefits. The district court affirmed. The Supreme Court reversed, holding (1) McMasters established a prima facie case under the odd lot doctrine when he showed he could not return to his former employment, and the combination of his psychological and physical conditions precluded alternative employment; (2) the burden thereafter shifted to the Division to show that light work of a special nature, which McMasters could perform, was available; and (3) the Division did not meet its burden. View "McMasters v. State ex rel. Workers' Safety & Comp. Div." on Justia Law

R & R Rig Service moved Universal Drilling Company's drilling rig under a time and materials contract. Universal refused to pay R & R's invoice, claiming that it should only have to pay the amount it paid to have the rig moved a few weeks later by a different company. R & R brought suit for payment of the services it rendered, and Universal counterclaimed on the basis of fraud and breach of the implied covenant of good faith and fair dealing. The district court generally ruled in favor of R & R and against Universal, although it refused to grant R & R's request for pre-judgment interest. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) did not err in awarding damages; (2) did not err in ruling that Universal had failed to prove its fraud claim; (3) properly denied Universal's claim for breach of the implied covenant of good faith and fair dealing; and (4) erred in denying R & R's request for prejudgment interest. Remanded with directions to award R & R prejudgment interest. View "Universal Drilling Co., LLC v. R & R Rig Serv., LLC" on Justia Law

The district court terminated Father's parental rights to his three children after finding by clear and convincing evidence that he was incarcerated for a felony conviction and was unfit to have the custody and control of the children. The Supreme Court affirmed, holding (1) the district court did not plainly err when it allowed a police report and the testimony of the officer who wrote the report into evidence; (2) the district court did not plainly err when it allowed into evidence the officer's testimony regarding the credibility of a victim's statement; and (3) Mother presented clear and convincing evidence that Father was unfit to have the custody and control of his children. View "M.S.H. v. A.L.H." on Justia Law