Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court answered a question of law regarding the relative priority of liens against real property as follows: A lien against real property created by a certificate of purchase for delinquent taxes pursuant to Wyo. Stat. Ann. 39-13-108(d)(ii) is superior to any lien held by the State of Wyoming, Department of Workforce Services under Wyo. Stat. Ann. 27-3-511(b) for unpaid contributions and interest to the unemployment compensation fund. The question was certified to the Court by the United States District Court for the District of Wyoming and conceded real estate in Uinta County and encumbrances against the property arising from the failure of a corporation to satisfy various financial obligations. View "Brock v. State, ex rel. Wyoming Workforce Services, Unemployment Insurance Division" on Justia Law

In this dispute between two neighboring Park County communities - the China Wall Tract and the Copperleaf Subdivision - the district court interpreted the China Wall Tract’s restrictive covenants in a manner that will allow Copperleaf property owners access to and through certain areas in the China Wall Tract. The Gumpel Family Trust, which owned property in the China Wall Tract, appealed. The Supreme Court affirmed, as modified, holding (1) the district court did not err in interpreting the covenants; but (2) the court’s holding is modified to clarify that an “invitee” and an “owner” do not share equivalent rights under the covenants. View "Gumpel v. Copperleaf Homeowners Ass’n, Inc." on Justia Law

Defendant was charged in the district court with criminal contempt for violating a juvenile court order. Defendant entered a conditional no contest plea to the criminal contempt charges. Defendant then timely appealed, raising several issues. The Supreme Court reversed, holding (1) Defendant’s entire plea was invalid, but the Court exercised its discretion to convert Defendant’s appeal to a writ of review in order to clarify some of the questions of law; (2) the district court had concurrent jurisdiction over this criminal contempt action arising from conduct in juvenile court; but (3) Defendant was denied due process because the order to show cause did not contain all the elements of the charged offense, an error that was compounded when Defendant’s attorney was denied access to the juvenile court file which contained the order Defendant was accused of violating. Remanded. View "Brown v. State" on Justia Law

Defendant was convicted of second-degree sexual assault of a minor. The district court sentenced Defendant to imprisonment for six to ten years. Defendant moved for a new trial on the ground that his trial attorney was ineffective. The district court denied the motion after an evidentiary hearing. The Supreme Court affirmed the conviction and sentence, holding (1) Defendant’s attorney provided constitutionally effective assistance; and (2) the evidence was sufficient to allow rational jurors to reasonably conclude beyond a reasonable doubt that Defendant caused the victim to touch him for sexual arousal or gratification. View "Jones v. State" on Justia Law

In 2013, Karen Hardy was injured during the course of her employment. In 2015, Hardy sought treatment for low back pain. The Department of Workforce Services, Workers’ Compensation Division denied payment for Hardy’s medical bills. The Office of Administrative Hearings (OAH) concluded that Hardy’s injury was not compensable because Hardy had failed to prove by a preponderance of the evidence a causal connection between her 2013 work-related injury and her 2015 back injury. The district court affirmed. Hardy appealed, arguing that she was entitled to benefits under the second compensable injury rule. The Supreme Court affirmed, holding that substantial evidence supported the OAH’s conclusion that Hardy failed to demonstrate that it was more probable than not that her 2013 injury was causally related to her 2015 injury. View "Hardy v. State ex rel. Department of Workforce Services, Workers’ Compensation Division" on Justia Law

After a jury trial, Appellant was convicted of felony exploitation of a vulnerable adult. On appeal, Appellant argued, inter alia, that the State did not present sufficient evidence to prove that the victim was a vulnerable adult. The Supreme Court affirmed, holding (1) the State presented sufficient evidence for the jury to find that the victim was a vulnerable adult as defined by statute; and (2) as regarding the jury instructions on the mental element required for conviction of felony exploitation of a vulnerable adult, the district court’s failure to edit the definition of exploitation to include only the intentional mental element did not prejudice Appellant. View "Blevins v. State" on Justia Law

While serving an eighteen to thirty-six-month sentence, Defendant escaped and kidnapped an elderly woman. Defendant entered a no contest plea to a kidnapping charge and a guilty plea to an escape charge. The district court sentenced Defendant to terms of years for both convictions, to run consecutive to each other and concurrent to his original sentence. The Supreme Court affirmed. Defendant later filed a pro se motion to correct an illegal sentence, requesting credit for time served between his arrest and his sentencing. The district court denied the motion. Defendant then filed a pro se motion seeking credit for 1,280 days, which was the same relief he sought in his motion to correct an illegal sentence. The court denied the motion. The Supreme Court affirmed, holding that res judicata prevented the Court’s review of the issue raised by Defendant. View "Majors v. State" on Justia Law

The State filed a petition alleging that Mother had neglected her two children. Mother admitted to the allegations of the neglect petition and agreed to complete a Department of Family Services (DFS) case plan. The State eventually filed a petition to revoke the consent decree. The juvenile court found the children to be neglected children and ordered that DFS would have legal and physical custody of the children. This appeal concerned the juvenile court’s order changing the permanency plan from reunification to adoption. The Supreme Court affirmed, holding (1) the juvenile court did not commit plain error when it did not make a determination prior to the hearing regarding the children’s attendance at the permanency hearing; (2) Mother was not denied due process of law when the permanency hearing was held without the children; and (3) there was sufficient evidence to support the juvenile court’s decision to change the permanency plan from reunification to adoption. View "ST v. State" on Justia Law

Mother and Father were divorced while both parties lived in Cody, Wyoming. The court awarded Mother custody of the parties’ children, and Father was awarded liberal visitation. Mother found a job in Arizona after unsuccessfully seeking suitable employment in Cody. Mother moved to Arizona with the children after giving Father notice of the move. Thereafter, Mother filed for a change in Father’s visitation. Father cross-filed for a change in custody and to have Mother held in contempt. The court concluded that it was in the children’s best interest for Mother to continue as the primary custodial parent, made modifications to the divorce decree to provide Father as much visitation as possible under the changed circumstances, and declined to hold Mother in contempt. Father appealed. The Supreme Court affirmed, holding (1) there was no abuse of discretion in the court’s determination to allow Mother to have continued primary custody; and (2) there was no basis to conclude that the district judge erred in refusing to hold Mother in contempt. View "Greer v. Greer" on Justia Law

Defendant pled guilty to two counts of first degree murder and one count of larceny. Defendant was eighteen years old when he committed the crimes. At that time, the age of majority in Wyoming was nineteen. Defendant was sentenced to two consecutive sentences of life imprisonment on the murder counts. Defendant later filed a pro se motion to correct an illegal sentence under Wyo. R. Crim. P. 35, arguing that his life sentences violated the constitutional prohibition of cruel and unusual punishment. The Supreme Court affirmed, holding that Defendant’s sentence did not violate state law because the Eighth Amendment sentencing protections announced in Miller v. Alabama extend only to offenders under the age of eighteen. View "Nicodemus v. State" on Justia Law