Justia Wyoming Supreme Court Opinion Summaries

Appellees, Shari and Steve Skaj, brought suit against Appellant Vincent Rosty to recover damages caused when an idling dump truck that had been driven by Appellant was knocked into gear, pinning Shari against a motor home. Appellant failed to plead or otherwise defend against the allegations in the complaint. The district court subsequently entered default judgment against Appellant and awarded damages to Appellees. The court then denied Appellant's motion to set aside entry of default or for relief from default judgment. On appeal, the Supreme Court affirmed in part and reversed in part, holding (1) Appellant's appeal was timely; (2) the district court did not violate Appellant's due process rights, as Appellant had adequate notice of the default judgment hearing and thus had a meaningful opportunity to be heard at the hearing; (3) Appellant was properly served with the summons and complaint; (4) the district court did not abuse its discretion by denying Appellant's motion to set aside entry of default and default judgment; and (5) the district court abused its discretion in awarding punitive damages, as Appellees failed to produce sufficient evidence of Appellant's wealth or financial condition to support an award of punitive damages. Remanded. View "Rosty v. Skaj" on Justia Law

Landlord leased commercial real property to Tenant. Landlord granted Tenant permission to renovate the property on the condition that Tenant would pay for the renovations. Tenant thereafter contracted with Contractor to perform the work. When Tenant defaulted on its payments to Contractor, Contractor filed a lien against Landlord's property. Contractor thereafter filed a complaint against Landlord and Tenant, asserting various claims and seeking to foreclose on its lien. The district court granted Landlord's motion for summary judgment, concluding that, pursuant to Wyoming's lien statutes, a valid mechanic's lien did not exist because Landlord did not agree to pay for the renovations to the property and that Tenant was not acting as Landlord's agent in contracting for the improvements. The Supreme Court affirmed, holding (1) the district court correctly interpreted Wyo. Stat. Ann. 29-2-105(a)(ii) to require a finding of agency between the landlord and tenant before a mechanic's lien may attach to the landlord's property for work performed at the tenant's behest; and (2) in this case, that relationship did not exist. View "Redco Constr. v. Profile Props., LLC " on Justia Law

After initiating a traffic stop, a highway patrol trooper found marijuana in Jason Holohan's vehicle. Holohan was charged with two counts of possession of a controlled substance with intent to deliver. Holohan filed a motion to suppress the evidence seized during the search of his vehicle, claiming the trooper lacked probable cause or reasonable suspicion to justify the traffic stop at the time he activated his flashing lights and could not use events occurring after activating his lights to justify the stop. The district court agreed and granted the motion. The Supreme Court reversed, holding (1) because Holohan did not submit to the trooper's show of authority in activating his lights, there was no Fourth Amendment seizure until the vehicle pulled off the highway and stopped; and (2) at the point that the vehicle pulled off the highway, the trooper had probable cause to stop the vehicle for weaving erratically and a reasonable suspicion of criminal activity based upon Holohan's failure to pull over in response to the flashing lights. View "State v. Holohan " on Justia Law

Appellant was physically injured as a result of an accident caused by an underinsured motorist. Prior to the accident, Appellant purchased a Dairyland Insurance Policy through his insurance agent, Jonathan Schrack. Although Appellant requested full coverage, the policy did not include underinsured motorist coverage. When the other driver's insurance did not fully cover Appellant's damages, Appellant sued Dairyland and Schrack (Defendants), raising numerous theories as to why he should recover under the Dairyland policy. The district court granted Defendants' motions for summary judgment. The Supreme Court affirmed, holding, inter alia, (1) Wyoming's uninsured motorist statutes unambiguously do not require insurers to provide underinsured motorist liability coverage; (2) Appellant's failure to read the policy was available as a defense to Defendants as to Appellant's negligence and contract claims against them and barred application of the doctrine of promissory estoppel; and (3) the doctrine of reasonable expectations was not available to alter the unambiguous terms of the policy. View "Broderick v. Dairyland Ins. Co." on Justia Law

Appellant, Whitney Holding Corporation, challenged a decision of the district court quieting title in a certain mineral estate in favor of Appellees, Clarence and Peggy Terry. The Supreme Court affirmed, holding (1) the district court did not err in concluding that the parties intended, and the limited warranty deed conveying the property from Whitney to the Terrys reflected, that Whitney did not reserve a mineral interest in the property; (2) the district court properly determined that the deed was ambiguous and did not err in considering extrinsic evidence to interpret the deed; and (3) the Terrys' quiet title action was not barred by the statute of limitations. View "Whitney Holding Corp. v. Terry" on Justia Law

Decedent died, leaving a house. A developer who claimed to have purchased the property from Decedent's daughter filed a petition for probate without administration of an alleged will of Decedent. Decedent's neighbors filed a petition to revoke the probate of the will, alleging that the will was invalid and that the probate court improperly admitted the will to probate. Decedent's son filed a motion to intervene and join as a petitioner seeking to revoke the probate. The probate court (1) concluded that it did not have jurisdiction to hear the neighbors' petition to revoke because they lacked standing; (2) granted the developer's motion to dismiss the petition to revoke the will; and (3) found that because the son, who did have standing, did not file his own motion challenging the will, the court's jurisdiction was not properly invoked. The Supreme Court reversed, holding (1) the son's pleading, in essence, was a petition to revoke, and it should have been treated as such; (2) the district court should have allowed intervention under the circumstances presented here; and (3) substitution of the son as the real party in interest should have been allowed in this case. Remanded. View "Russell v. Kellersman" on Justia Law

Appellant Roger Snow was convicted of felony burglary and a related misdemeanor. Snow appealed, contending that the district court erred when it denied his request for a new attorney and that he received ineffective assistance of counsel. The Supreme Court affirmed, holding (1) the district court met its obligation to inquire about Snow's request for substitute counsel, and therefore the court did not abuse its discretion in addressing Snow's desire for substitute counsel; and (2) Snow failed to show he was entitled to a lesser-included offense instruction, or that his attorney's failure to request such an instruction so prejudiced him as to require reversal. View "Snow v. State" on Justia Law

Randall and Carmen Sinclair brought an action against the City of Gillette asserting three claims for relief, including a claim for damages under the Wyoming Governmental Claims Act. The Act provides broad governmental immunity from tort liability but also establishes a number of specified exceptions. The City asserted governmental immunity and moved to dismiss that claim. The district court granted the motion. The Supreme Court affirmed the district court's order dismissing the claim, holding that the court did not err in finding the Sinclairs' claim was not cognizable under the exception to immunity specified in the Act that allows claims for public employees' negligence while acting within the scope of their duties in the operation of public utilities and services because, in this case, the City's negligence was unrelated to the operation of the storm drain. View "Sinclair v. City of Gillette" on Justia Law

After a jury trial, Appellant Carl Peterson was convicted of second degree sexual abuse of a minor and soliciting a minor to engage in sexual relations. Peterson appealed, raising multiple allegations of ineffective assistance of trial counsel. The Supreme Court affirmed the convictions, holding (1) Peterson failed to demonstrate that counsel's investigation and evaluation of a witness's likely testimony was flawed and outside the realm of professionally competent assistance; (2) Peterson failed to show that counsel was ineffective at the victim's competency hearing; (3) trial counsel was not ineffective in his cross-examination of the victim; and (4) counsel was not ineffective in his questioning of jurors during the voir dire process. View "Peterson v. State" on Justia Law

Appellant Wyatt Bear Cloud and two co-defendants were involved in an armed burglary of a residence in which one of Bear Cloud's co-defendants shot and killed one of the home's residents. Bear Cloud, who was sixteen years old at the time of the offenses, ultimately pleaded guilty to felony-murder, conspiracy to commit aggravated burglary, and aggravated burglary. Bear Cloud was sentenced to life imprisonment for his conviction for felony-murder. The Supreme Court affirmed Bear Cloud's convictions and sentences in their entireties, holding, inter alia, (1) Appellant's trial counsel was not ineffective in her representation of Bear Cloud; (2) the trial court did not abuse its discretion when it refused to transfer proceedings to juvenile court; (3) a life sentence for a juvenile who did not commit homicide does not violate the Eighth Amendment of the federal constitution or Wyo. Const. art. I, 14; and (4) Wyo. Stat. Ann. 6-2-101(b) is not rendered unconstitutional by its mandatory sentencing structure, even as applied to a juvenile offender, and particularly in light of the district court's ability to consider mitigating circumstances when considering whether to transfer proceedings to juvenile court. View "Bear Cloud v. State" on Justia Law