Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of five counts of sexual assault and sexual abuse of a minor. Defendant appealed, arguing that he was denied his right to a fair trial due to the cumulative error of three instances of prosecutorial misconduct during the prosecutor’s closing argument. The Supreme Court affirmed, holding (1) the prosecutor committed misconduct by attempting to define reasonable doubt for the jury; (2) the prosecutor committed misconduct by suggesting that Defendant carried any burden of proof; but (3) Defendant was not cumulatively prejudiced by the prosecutor’s statements to such an extent that his trial was anything other than fair and impartial. View "Hamilton v. State" on Justia Law

Defendant pleaded no contest to second-degree murder. After Defendant was sentenced, the State and Defendant filed a joint motion to correct an illegal sentence, agreeing that Defendant had not been sentenced in accordance with the terms of his plea agreement. Dissatisfied with his stipulated sentence amendment, Defendant filed a motion to vacate an illegal sentence and a motion to withdraw his no contest plea. The district court denied the motion. The Supreme Court affirmed, holding (1) the district court lacked jurisdiction to consider Defendant’s post-sentence motion to withdraw his guilty plea because Defendant’s post-sentence motion was untimely; and (2) accordingly, this court lacked jurisdiction to consider Defendant’s appeal. View "Sanchez v. State" on Justia Law

Appellant pled guilty to six counts of second-degree sexual assault in 2000 and was sentenced to six consecutive life sentences. The current matter began when Appellant filed a Wyo. R. Crim. P. 36 motion requesting that the spelling of his surname in his judgment and sentence order be corrected from DELOGE to DeLoge or De Loge. The district court denied the motion, explaining that capitalization in the caption on court documents is not a clerical error. The Supreme Court affirmed, holding that the district court did not misspell Appellant’s name when it capitalized its letters, and therefore, there was no clerical error in the judgment and sentence. View "DeLoge v. State" on Justia Law

Collateral estoppel is not given effect to an uncontested Wyoming Workers’ Compensation Division (Division) determination denying workers’ compensation benefits even when the denial is based on a finding that the employee did not suffer a compensable injury.Lea Porter, through her employer, submitted a report of injury to the Division, by which Porter reporter an injury to her left knee. The Division issued to Porter final determination informing her that it would not approve payments of benefits upon its determination that the injury was not a work-related injury. Porter did not object to the final determination or request a hearing but did object to a later final determination of the Division that denied payment of costs related to an MRI of her left knee. The Office of Administrative Hearings granted summary judgment for the Division, concluding that Porter could not challenge the denial of benefits for the MRI because she did not object to the Division’s earlier determination that her injury was not work related. The district court affirmed. The Supreme Court reversed, holding that Porter’s failure to object to the Division’s compensability determination did not preclude her objection to the Division’s final determination denying benefits to cover her MRI costs. View "Porter v. State ex rel. Department of Workforce Services" on Justia Law

Defendant, who received state and federal convictions for drug and firearm offenses, filed a motion for a sentence reduction, asking that his aggregate state sentence be altered to run concurrently with the federal sentence he was then serving so that he might be eligible to participate in his federal facility’s drug treatment program earlier. The district court denied the motion without a hearing, concluding that no showing had been made pursuant to W. R. Crim. P. 35(b) to justify or require a reduction of Defendant’s sentence. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in declining to run the Wyoming sentence concurrently with the federal sentence without holding a hearing; and (2) as to Defendant’s remaining issues on appeal, they were not raised in the district court, and Defendant now offered no cogent argument or pertinent authority in support of his position. View "Simms v. State" on Justia Law

Plaintiff filed a declaratory judgment action against the Teton County Assessor seeking a declaration that the trusts for which it acted as trustee were charitable trusts within the meaning of Wyo. Stat. Ann. 4-10-406(a) and were exempt from taxation under Wyo. Stat. Ann. 39-11-105(xix). The district court dismissed the complaint, concluding that the primary jurisdiction doctrine made dismissal of the action appropriate. The Supreme Court affirmed, holding (1) because Plaintiff failed to exhaust its administrative remedies before filing a complaint in the district court, the district court properly dismissed the complaint; and (2) to the extent Plaintiff may have properly invoked the district court’s jurisdiction the district court did not abuse its discretion in concluding that the primary jurisdiction doctrine warranted dismissal of the action in favor of review through the administrative process. View "Thomas Gilcrease Foundation v. Cavallaro" on Justia Law

Mother appealed after the district court entered an order terminating Mother’s parental rights. The order followed a jury verdict finding that the Department of Family Services had proven two statutory grounds to terminate Mother’s parental rights to Child. The Supreme Court affirmed, holding that the district court did not err (1) when it allowed the guardian ad litem (GAL) to actively participate in the termination proceedings where the GAL was required to participate fully in the termination proceedings; and (2) when it allowed Mother’s mental health providers to testify at trial over Mother’s claim of privilege. View "Cave v. State, Department of Family Services" on Justia Law

In 1995, Appellant pled guilty to second-degree murder. In 2016, Appellant filed the two motions at issue in this appeal. The first motion was a request that the district court order the Wyoming Department of Corrections to provide a copy of all of Defendant’s records at the State’s expense. The second motion was “time line…on how much time the Defendant would have to serve” and an order requiring that he receive parole. The district court denied both motions. The Supreme Court dismissed the appeal, holding that the district court had no jurisdiction to consider either of Appellant’s motions because appellant provided no cogent argument or relevant authority demonstrating that the district court had jurisdiction to grant the relief he requested. The court further ordered Appellant to show cause why the filing restrictions stated in this opinion should not be imposed. View "Barela v. State" on Justia Law

Appellant appealed his convictions for kidnapping and misdemeanor theft of a cell phone, arguing that there was insufficient evidence to support the convictions. The Supreme Court affirmed, holding (1) a reasonable jury could have found from the facts presented that the time the victim was forced to spend in her house with Appellant was sufficient to constitute confinement within the meaning of Wyoming’s kidnapping statute; and (2) there were sufficient facts for a jury to reasonably conclude that each of the elements of misdemeanor theft relating to the taking of an Apple iPhone was proven beyond a reasonable doubt. View "Dockter v. State" on Justia Law

Appellant entered into a lease with a Mall to operate a restaurant. The lease required Mall to pay Appellant a finish allowance when certain provisions had been satisfied. The condition at the heart of this dispute required Appellant to provide the Mall evidence that any liens had been satisfied or waived and that “all work has been paid for” before the finish allowance became due. Appellant hired a general contractor to renovate the space. Appellant paid the general contractor in full, but the general contractor did not pay all of the subcontractors. When the Mall did not pay the finish allowance, Appellant filed this lawsuit alleging, inter alia, breach of contract. The district court granted summary judgment in favor of the Mall. The Supreme Court affirmed, holding that the unambiguous terms of the lease required evidence that the general contractor and subcontractors had been paid in full before the Mall was obligated to pay the finish allowance. View "P & N Investments, LLC v. Frontier Mall Associates, LP" on Justia Law