Justia Wyoming Supreme Court Opinion Summaries

Appellants sought the establishment of a private road along the upper portion of Black Mountain Road in Big Horn County, but the Big Horn County Board of County Commissioners established a private road along the lower portion of Black Mountain Road. Appellants argued that the route was illogical, unproductive, and uneconomic and was procedurally barred. The Supreme Court affirmed, holding (1) because the district court’s earlier decision in a decision letter did not address the question of whether the proposed private road was reasonable or convenient, collateral estoppel and law of the case did not apply; and (2) the Board’s conclusion that Lower Black Mountain Road was more reasonable and convenient than Upper Black Mountain Road was supported by substantial evidence. View "Whaley v. Flitner Limited Partnership" on Justia Law

Appellants sued the town of Alpine, alleging claims stemming from Alpine’s financing and construction of a new sewage treatment facility. Appellants sought a declaration that Alpine’s loans for the new sewage treatment facility exceeded the town’s constitutional and statutory indebtedness limits. Appellant’s also asserted a claim for injunctive relief to stop Alpine from enforcing assessments and exactions for the new sewerage system on Appellants. A few years later, while the original case was proceeding, Appellants filed another action against Alpine and Nelson Engineering, claiming that Alpine and Nelson made false reports to the Wyoming Department of Environmental Quality that Appellants had violated the agency’s rules and regulations when they upgraded their septic systems. The district court granted Alpine’s motion to dismiss all claims against the town and granted Nelson’s motion for summary judgment on all claims against the engineering firm. The Supreme Court affirmed in part and reversed in part, holding (1) Appellants sufficiently pled standing to pursue their declaratory judgment claim against Alpine; (2) the allegations supporting Appellants’ claim for injunctive relief against Alpine were legally sufficient; and (3) the district court’s respective orders on all the remaining claims in the two cases against Alpine and Nelson were not in error. View "Tavern, LLC v. Town of Alpine" on Justia Law

Wallace Burnett, who owned eleven of the 604 outstanding shares of Burnett Ranch, Inc., filed suit against his three siblings and his son, who owned the other shares. Burnett presented claims for, inter alia, a preliminary injunction to prevent the transfer of corporate assets, an accounting, and a winding-up of the corporation and sale of its assets. The district court granted Defendants’ motion to dismiss. The Supreme Court affirmed, holding that Burnett failed to provide cogent argument to support his claims on appeal and failed to comply with the Wyoming Rules of Appellate Procedure. Burnett’s failures led the court to certify that there was no reasonable cause for this appeal and to award penalties in accordance with Wyo. R. App. P. 10.05(b). View "Burnett v. Burnett" on Justia Law

Clare Sikora filed a declaratory judgment action against the City of Rawlins challenging the City’s issuance of a building permit to her next-door neighbors, Jared and Kasandra Ramsey. The district court ruled in favor of the City. The Supreme Court affirmed, holding (1) the district court properly found that Sikora failed to exhaust her administrative remedies; and (2) the district court did not err in finding that the the municipal ordinance governing restoration of a nonconforming building allows for demolition of the nonconforming building and reconstruction of the building within the same footprint - the type of construction undertaken by the Ramseys. View "Sikora v. City of Rawlins" on Justia Law

After the State filed a petition alleging that Mother had neglected her children, the juvenile court entered a consent decree providing that if would be in effect for six months and shall expire and the action be deemed dismissed “if no further action is taken in this matter.” When the consent decree had been effect for six months, and the State hd not taken any additional action, Mother filed a motion to dismiss. The juvenile court denied Mother’s motion to dismiss, granted the State fifteen days to file an amended neglect petition, and extended the consent decree for another six months. After Mother filed a motion of appeal, the children were returned to Mother, and the juvenile court closed the case. The State moved to dismiss Mother’s appeal, asserting that the return of the children to Mother and the closure of the case rendered the case moot. The Supreme Court denied the State’s motion to dismiss, holding (1) an exception to the mootness doctrine applies; and (2) on the merits, the juvenile court was not authorized to extend the expired consent decree under the applicable statutes or pursuant to the decree’s terms. View "In re Interest of DJS-Y v. State" on Justia Law

The Supreme Court affirmed the district court’s order terminating the parental rights of Father, the non-custodial parent to his child, under Wyo. Stat. 14-2-309(a)(i) and (iv). The petition seeking termination of Father’s parental rights was filed by Mother. The Supreme Court held (1) the evidence presented at trial was sufficient to establish grounds for termination under section 14-2-309 by clear and convincing evidence; and (2) the district court did not err in failing to require Mother to pursue remedies other than termination of parental rights, as section 14-2-309(a)(i) does not impose such a requirement. View "Johnson v. Calkins" on Justia Law

The Supreme Court reversed Appellant’s convictions for involuntary manslaughter and reckless endangerment. On appeal, Appellant challenged the district court’s jury instructions on self-defense. The Supreme Court held (1) the justification of self-defense is available when the crime charged involves a reckless act rather than an intentional act, and therefore, the Court’s conclusion to the contrary in Duran v. State is hereby overruled; (2) the district court did not err in failing to give the jury a requested castle doctrine instruction; but (3) plain error occurred when the jury was instructed that Appellant had a duty to retreat before using deadly force. View "Haire v. State" on Justia Law

In this dispute between property owners regarding a mistaken property boundary, the district court concluded that Appellees had acquired title to the property at issue by adverse possession. The Supreme Court affirmed, holding (1) contrary to Appellants’ arguments, Appellees’ possession of the property was “hostile,” and the conveyance of the property to Appellants by their predecessors in interest did not divest Appellees of any claim they had to the property by adverse possession; and (2) Appellees’ request for sanctions under Wyo. R. Civ. P. 10.05 is denied because the Court cannot certify that Appellants had no reasonable cause for this appeal. View "Osuch v. Gunnels" on Justia Law

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