Justia Wyoming Supreme Court Opinion Summaries

After Crook County Weed and Pest Control District applied herbicides to control leafy spurge found on property owned by Bush Land Development Company and Victoria Bush (collectively, Bush), many trees in the area of the spraying died. Bush filed this inverse condemnation action in the district court alleging that it was entitled to just compensation for the loss of its trees as a result of the District’s improper application of herbicides. The district court dismissed Bush’s claim, concluding that the action was not proper under the inverse condemnation statute. The Supreme Court affirmed on other grounds, concluding that the inverse condemnation was not properly before the district court because Bush failed to exhaust its administrative remedies before claiming inverse condemnation. View "Bush Land Development Co. v. Crook County Weed & Pest Control District" on Justia Law

In 1951, the State issued two oil and gas leases covering land in Sublette County. One of these leases (the 505 Lease) covered 160 acres, and the other lease (the 529 Lease) covered 480 acres. The leases were later assigned to Continental Oil Company, and the assignor, Walter Davis, reserved a four percent overriding royalty interest in both leases. Davis’s mineral interests were later awarded to Robert Floyd. In 1979, after the 505 and 529 Leases terminated and the acreage was combined into a single parcel, the State granted Dr. Robert Ribbe Lease 79-0645, which covered all 640 acres. In 2011, Robert Floyd filed suit, arguing that Davis’s four percent overriding royal interest should have attached to the Ribbe Lease. The district court concluded that Appellants, QEP Energy Company and Wexpro Company, were liable for more than thirty million dollars in unpaid royalties. The district court denied Appellants’ motion for a new trial. The Supreme Court reversed, holding that the Ribbe lease was not a renewal lease, substitute lease, or new lease issued in lieu of the 505 and 529 Leases, and therefore, the overriding royalty interest did not attach to the Ribbe Lease. View "Questar Exploration & Production Co. v. Rocky Mountain Resources, LLC" on Justia Law

Defendant entered a conditional no contest plea to possession of methamphetamine with the intent to distribute. Defendant appealed, arguing that the district court erred in denying his motion to suppress and finding that Defendant consented to continued detention when law enforcement told him “he was free to leave” but continued to have [its] red and blue emergency overhead lights activated. The Supreme Court affirmed, holding that, under the totality of the circumstances in this case, a reasonable person in Defendant’s position would have felt free to decline the law enforcement officer’s request, and therefore, the contact between the officer and Defendant was consensual. View "Tibbetts v. State" on Justia Law

Appellant Bruce Williams asked the Circuit Court for a copy of part of a presentence investigation report in a criminal case. The circuit court denied his request. He brought a petition for a writ of mandamus asking the district court to require that the circuit court release the records. The district court dismissed the case. He appealed, claiming a constitutional right as a member of the public to access these records. Because he did not present his constitutional arguments to the district court, the Supreme Court affirmed. View "Williams v. Tharp" on Justia Law

Defendant was convicted of four felony counts of obtaining property by false pretenses and one misdemeanor count of official misconduct. Defendant appealed, arguing that the State was required to prove that the title to the property at issue passed from Albany County to him and that the State failed to prove that it did. The Supreme Court (1) reversed the four felony convictions, holding that there was insufficient evidence to prove beyond a reasonable doubt that Defendant committed the crime of obtaining property by false pretenses, and (2) the Court declines to consider Defendant’s claim regarding the misdemeanor conviction of official misconduct because Defendant failed to provide cogent argument on this issue. View "Bohling v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of felony interference with a peace officer, one count of misdemeanor interference with a peace officer, and one count of misdemeanor simple assault. The Supreme Court affirmed, holding (1) the district court did not err in failing to give the jury Defendant’s proposed theory of defense instructions; and (2) Defendant’s Sixth Amendment right to effective assistance of counsel was not violated by trial counsel’s failure to file a motion to suppress, renew the motion for judgment of acquittal at the end of trial, and propose certain theory of defense instructions. View "Tingey v. State" on Justia Law

Appellant, a coal producer that reports the taxable value of its coal to the Department of Revenue using the proportionate profits valuation method, challenged two of the Departments determinations, arguing (1) the Department improperly applied Wyoming law when it set the point of valuation for its coal for production years 2009 through 2011; and (2) the Department improperly categorized certain government-imposed and environmental expenses in the tax valuation formula. The Board of Equalization upheld the Board’s determinations. The Supreme Court affirmed, holding (1) the Board correctly upheld the Department’s decision on the point of valuation; and (2) the Board’s decision on the categorization of the environmental and government-imposed expenses was not final, and the issue was not ripe for judicial review. View "Wyodak Resources Development Corp. v. Wyoming Department of Revenue" on Justia Law

Defendant was convicted of felony possession of methamphetamine and possession of methamphetamine with intent to deliver. Defendant appealed his conviction on the charge of possession with intent to deliver, arguing that the district court erred when it admitted evidence of a prior drug transaction. Further, Defendant claimed that because felony possession is a lesser included offense of possession with intent to deliver, the district court erred in convicting and sentencing him on both counts. The Supreme Court reversed Defendant’s conviction for possession with intent to deliver, holding (1) the district court erroneously admitted the evidence of Defendant’s prior drug transaction; and (2) it is therefore unnecessary to consider Defendant’s second issue. View "Overson v. State" on Justia Law

In 2004, KGS was born to Father and Mother. In 2013, a neglect petition was filed against Mother and, after a hearing, KGS was placed in the legal custody of the Department of Family Services. The Department later filed a petition seeking termination of Mother’s and Father’s parental rights. After a hearing, the district court entered an order terminating Father’s parental rights. Father appealed. The Supreme Court affirmed, holding (1) the Department presented sufficient evidence to support termination of Father’s parental rights; and (2) Father failed to show that he was denied due process in this case. View "In re Termination of Parental Rights to KGS" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree sexual assault and one count of battery of a household member. The Supreme Court affirmed, holding (1) trial counsel for Defendant did not provide ineffective assistance when he failed to challenge the credibility of the alleged victim; (2) Defendant failed to establish that the State committed a violation of Brady v. Maryland when the prosecutor allegedly failed to disclose exculpatory evidence relating to the alleged victim; and (3) the State presented sufficient evidence to support Defendant’s conviction for battery of a household member. View "Worley v. State" on Justia Law