Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of aggravated assault and battery. On appeal, Appellant argued that the district court erred by denying his motion to continue his jury trial to allow newly retained counsel additional time to prepare for trial and that the jury's special verdict findings contained inconsistencies that required a new trial. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in denying Appellant's motion to continue his jury trial; and (2) there was no plain error in alleged inconsistencies in the jury's special verdict findings form. View "Secrest v. State" on Justia Law

Upon Father's and Mother's divorce, the parties executed a settlement agreement that awarded Mother primary residential custody of the two children. The agreement was incorporated into the parties' divorce decree. Father later filed a petition to modify the divorce decree, seeking custody of the children. Prior to a hearing, the parties resolved their custody issues. The district court then entered an order interpreting the divorce decree provisions that governed payment of counseling and medical expenses for the parties' children. Father appealed, contending (1) because this case was submitted to the court as a stipulated or agreed case and only queried the meaning of "counseling" generally, the district court improperly answered the question in the context of the parties' dispute; and (2) the court erred in considering extrinsic evidence in analyzing the settlement agreement and in denying Father's motion for a continuance at the hearing. Because Father failed to submit a hearing transcript or statement of evidence, the Supreme Court affirmed, holding (1) no error of law appeared on the record; and (2) in this purported agreed on case, the context presented to the district court was presumptively adequate to satisfy the requirements of Koontz v. South Superior. View "Samiec v. Fermelia" on Justia Law

Appellant was employed as an iron worker when he injured his neck. Appellant received temporary total disability (TTD) benefits for thirty-six months, after which he underwent shoulder surgery. Appellant subsequently filed an application with the Wyoming Workers' Safety and Compensation Division for additional benefits, arguing that his shoulder surgery was a second compensable injury and, therefore, he was entitled to a separate period of benefits. The Office of Administrative Hearings (OAH) agreed that the shoulder surgery was a second compensable injury and that the thirty-six month time limitation on Appellant's TTD benefits was inapplicable. The district court affirmed the OAH's determination that Appellant's shoulder injury constituted a second compensable injury but concluded that the time limitation did apply to Appellant's benefits. The Supreme Court affirmed, holding that because Appellant's shoulder injury was a result of the same accident that caused his neck injury, he was not entitled to an additional period of benefits. View "Picozzi v. State ex rel., Wyo. Workers' Safety & Comp. Div." on Justia Law

After a jury trial, Appellant was convicted of three counts of first-degree sexual abuse of a minor. Appellant appealed, raising four separate allegations of error, including the allegation that the district court erred when it reversed itself on a prior ruling and admitted uncharged misconduct evidence. The Supreme Court reversed on that single issue, holding that the district court abused its discretion when, under the circumstances of this case, it reversed its prior ruling after the State had rested and admitted certain uncharged misconduct evidence under Wyo. R. Evid. 404(b), as the record did not show good reason existed for the reversal and the evidence was clearly prejudicial. View "Munoz v. State" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree. Defendant appealed, asserting that the district court abused its discretion by allowing a sexual assault nurse examiner to testify as to statements made by the victim during the physical examination of her. Specifically, Defendant contended that the district court did not properly apply the exception and foundational requirements of Wyo. R. Evid. 803(4), which allows a hearsay exception for statements for purposes of medical diangosis. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it determined that statements made by the victim during her sexual assault examination were admissible under Rule 803(4). View "McLaury v. State" on Justia Law

In 1988, Appellant injured his lower back while working for a paving company. Appellant underwent lumbar surgery in 1989 and, afterward, did not require additional treatment for his back surgery for several years. In 2007, an internist diagnosed Appellant with an arthritic hip and recommended a hip replacement. Appellant submitted a bill for the office visit to the Wyoming Workers' Safety and Compensation Division, which declined to pay the bill on the grounds that the hip condition was unrelated to the original work injury. After a contested case hearing, an Office of Administrative Hearings hearing examiner found that Appellant's arthritic hip was not related to the original compensable injury, and therefore, Appellant was entitled to benefits. The district court affirmed. The Supreme Court affirmed, holding that substantial evidence supported the hearing examiner's findings and conclusions. View "Little v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

In 1996, Appellant suffered a work-related back injury and sought benefits from the Wyoming Workers' Safety and Compensation Division. In 2009, Appellant began to experience significant lower back pain after shoveling snow. Appellant attempted to reopen her 1996 worker's compensation case to obtain payment for treatment of her recent back pain. The Division refused to reopen the case and denied Appellant's claims for benefits because more than four years had passed since she last sought benefits for her 1996 injury and because she failed to show her current injury was directly related to the 1996 injury. After a contested case hearing, the Office of Administrative Hearings (OAH) upheld the decision. The district court affirmed. The Supreme Court affirmed the district court, holding (1) the OAH's decision was not contrary to law and was supported by substantial evidence; (2) the OAH hearing examiner did not act arbitrarily and capriciously or abuse his discretion; and (3) the hearing examiner's findings of fact were sufficient. View "Leavitt v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Father filed suit to establish his paternity of ARF. Father sought custody of ARF and asked the district court to order Mother to pay child support. After Mother admitted Father's paternity and asked the district court to order Father to pay child support, the district court granted custody to Mother, ordered Father to pay child support, and found Father owed additional child support for previous years. The Supreme Court (1) affirmed the district court's decisions with respect to custody and its imposition of time limits on the parties' trial presentations; but (2) reversed the district court's child support decision, holding that the court's order did not comply with the statutory mandate to set forth the presumptive child support amount. Remanded. View "In re ARF" on Justia Law

Appellant entered a conditional plea to felony possession of methamphetamine. Appellant appealed, contending that the district court erred by denying his motion to suppress the results of a vehicle inventory that preceded the planned impoundment of the vehicle but after Appellant had been arrested. Specifically, Appellant argued that the impoundment of his vehicle was unnecessary, that the search was conducted in bad faith, and that police officers should be required to inquire into less intrusive means of safeguarding a vehicle before inventorying one in anticipation of impoundment. The Supreme Court affirmed, holding (1) inventory of a vehicle's contents pending impoundment is constitution when it is authorized by statute or when it is conducted pursuant to the general policy of a law enforcement agency; (2) the state trooper in this case had a statutory basis to impound the vehicle and was required by Highway Patrol policy to inventory the vehicle's contents before impounding it; and (3) the district court did not clearly err in ruling that the trooper acted in good faith. View "Hunnicutt-Carter v. State" on Justia Law

Appellant, who suffered from cystic fibrosis, was employed as a police officer when he broke his hand during a training session. About a month later, Appellant was admitted to the hospital, where he was treated for "pneumonia, sinusitis with cystic fibrosis." The Workers' Safety and Compensation Division granted benefits for the medical treatment associated with Appellant's broken hand but denied benefits for his hospitalization and associated treatment on the grounds that the treatment for pneumonia and cystic fibrosis was not related to his work injury. The Office of Administrative Hearings (OAH) upheld the denial of benefits, and the district court affirmed. The Supreme Court affirmed, holding that the OAH did not err by failing to find a causal connection between Appellant's work injury and his later medical conditions. View "Hayes v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law