Justia Wyoming Supreme Court Opinion Summaries

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

This action stemmed from Defendants’ financing of Plaintiffs’ real property located in Wyoming and California. Plaintiffs filed this action in Wyoming against Defendants alleging breach of contract, fraud in the inducement, and violation of a California law governing fraudulent business practices. Plaintiffs sought monetary and punitive damages, rescission and restitution, and an order declaring all encumbrances recorded against their Wyoming property void and expunged. After applying Wyoming law, the district court granted Defendants’ motions to dismiss and for judgment on the pleadings, concluding that Plaintiffs’ breach of contract claims were barred by the statute of frauds and that Plaintiffs failed to plead their fraud and fraud-based claims with the particularity required by Wyo. R. Crim. P. 9(b). View "Elworthy v. First Tennessee Bank" on Justia Law

Mother and Family divorced in 2013. In 2015, Mother filed a motion for an order to show cause as to why Father should not be held in contempt of court, asserting that Father had failed to pay amounts owed under the divorce decree for the expenses of the parties’ two children. The district court found Father in contempt for failing to pay certain expenses and also found Father in contempt for failure to pay child support. The court ordered that, in order to purge the contempt, Father was to pay not less than $50 monthly towards the child support arrearages and ordered that interest would not accrue on the delinquent amount as long as Father made the required payments. The Supreme Court reversed, holding (1) Mother had a judgment on the child support arrears as they became due, and the district court’s order was in error to the extent it impeded Mother’s right to execute on the judgment; and (2) Mother was entitled to interest on the arrears. Remanded. View "Rambo v. Rambo" on Justia Law

Louise Galiher sued to quiet title to a portion of her property, alleging that the use of the disputed portion of her property by Dennis Johnson and his wife had been permissive. The Johnsons counterclaimed seeking to quiet title to the disputed parcel based upon adverse possession. After a bench trial, the district court concluded that the Johnsons had proven their adverse possession claim. The Supreme Court reversed, holding that the district court committed prejudicial error when it determined it could not consider Johnson’s out-of-court statements as evidence that his use of the disputed property had always been permissive. Remanded. View "Galiher v. Johnson" on Justia Law

David Halling and Joyce Halling each purchased from Brandon Bentley an undivided half interest in certain property. Joyce, individually and as president of MedCon, Inc. (MedCon), executed a promissory note and mortgage as security for the note in favor of Bentley and for the purchase price of fifty percent of the lot. David, individually and as manager of Professional Business Holdings, LP (PBH), executed a mortgage in favor of Bentley on PBH’s half interest as security for the purchase price of the other fifty percent. Thereafter, Bentley assigned his rights and interests in the PBH mortgage to a bank and his rights and interests in the MedCon note and mortgage to David Yovanovich. Yovanovich sued MedCon, alleging that it failed to pay the amount due under the note. The district court granted summary judgment for Yovanovich. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err in concluding that Yovanovich had an enforceable contract against MedCon and that the Yovanovich assignment was not ambiguous; (2) the court’s damages calculation was not clearly erroneous; (3) the court erred when it failed to award prejudgment interest; and (4) the court did not err when it failed to specify post-judgment interest in its order. Remanded. View "Halling v. Yovanovich" on Justia Law

Appellant was adjudicated a delinquent juvenile for committing a sexual offense that required him to register as an offender under the Wyoming Sexual Offender Registration Act (WSORA). Appellant later entered a conditional guilty plea to two felony counts for failing to report changes in his address, as required by the WSORA. Appellant appealed his convictions, claiming that the WSORA is unconstitutional. The Supreme Court affirmed, holding (1) the Wyoming Juvenile Justice Act does not conflict irreconcilably with the WSORA’s registry requirements for adjudicated juvenile offenders; (2) the WSORA does not violate the Wyoming Constitution’s equal protection clause; (3) Appellant failed to establish that the WSORA’s lifetime registration requirement violates his due process rights; and (4) the WSORA does not violate the ex post facto clause of the United States Constitution. View "Vaughn v. State" on Justia Law

Appellant was convicted of first-degree felony murder, aggravated burglary, and conspiracy to commit aggravated burglary. After the United States Supreme Court’s decision in Miller v. Alabama and the Supreme Court’s decision in Bear Cloud v. State, the Supreme Court vacated Appellant’s sentences for resentencing on all counts. Upon resentencing, the court sentenced Appellant to an aggregate sentence will require him to serve at least thirty-five years before he becomes parole eligible. Appellant appealed, arguing that his aggregate sentence violates constitutional protections against cruel and unusual punishment. The Supreme Court affirmed, holding (1) Appellant’s aggregate sentence is not a de facto sentence of life without the possibility of parole and does not violate the Eighth Amendment; and (2) Appellant’s aggravated burglary sentence of ten to twenty-five years is not grossly disproportionate or unconstitutional. View "Sen v. State" on Justia Law

In 2014, a newspaper reporter asked Judge Ruth Neely, a municipal court judge and part-time circuit court magistrate, if she was “excited” to be able to perform same-sex marriages. Neely answered that she would not perform same-sex marriages in her judicial capacity as a part-time circuit court magistrate due to her religious beliefs. The matter came to the attention of the Wyoming Commission on Judicial conduct and Ethics. After an investigation, the Commission’s Investigatory Panel determined that there was probable cause to find a violation of the Wyoming Code of Judicial Conduct. The Commission’s Adjudicatory Panel granted the Commission’s motion for partial summary judgment. The full Commission adopted the Adjudicatory Panel’s findings and recommendations and recommended that Judge Neely be removed from her positions as municipal court judge and part-time circuit court magistrate. The Supreme Court affirmed, holding that Judge Neely violated the Wyoming Code of Judicial Conduct by announcing that she would perform marriages only for opposite-sex couples. The Court, however, did not accept the Commission’s recommendation for removal, and, instead, order public censure with specific conditions. View "Inquiry Concerning Honorable Ruth Neely" on Justia Law

The juvenile court adjudicated Father a neglectful parent to his two children. On appeal, Father argued that he could not be neglectful under the applicable statutes because he did not have physical custody or control of the children at the time that the allegedly neglectful behavior occurred. The Supreme Court affirmed, holding (1) the applicable statutes do not require that a child’s parent or noncustodial parent have actual physical custody or control of the children in order to be found to have neglected the children; and (2) accordingly, the juvenile court correctly interpreted the statute. View "TW v. State" on Justia Law

The parties in this case disputed title to certain mineral interests underlying certain property. The dispute arose out of a 1911 Laramie County tax assessment against Union Pacific’s mineral interests in the property and the county’s subsequent tax sale and issuance of a tax deed for the property. Family Tree Corporation, which claimed title to portions of the minerals, filed a complaint for quiet title and declaratory judgment against Three Sisters LLC, which also claimed an ownership in the minerals, and Anardarko Land Corporation. The district court quieted title to Family Tree based upon the 1912 tax sale. Anadarko appealed, arguing that the 1911 tax assessment against the minerals was unconstitutional, and therefore, the resulting tax sale and deed were void. The Supreme Court affirmed after drawing the line between a tax assessment defect that will render a tax deed void and one that will render the tax deed viable, holding (1) the error in Laramie County’s tax assessment against the minerals at issue rendered the resulting tax deed voidable, not void; and (2) accordingly, Anadarko’s challenge to the validity of the tax deed was barred by the statute of limitations. View "Anadarko Land Corp. v. Family Tree Corp." on Justia Law