Justia Wyoming Supreme Court Opinion Summaries

Appellant was charged with felony possession of methamphetamine and misdemeanor interference with a peace officer. Appellant’s appointed counsel moved to suspend proceedings pending a competency evaluation. The trial court granted the motion. After a competency evaluation and competency hearing, the court found Appellant competent, and the matter proceeded to trial. The jury found Appellant guilty of interference with a peace officer, but a mistrial was declared on the possession charge. Thereafter, defense counsel suggested that a second competency evaluation was needed. The court ultimately concluded that a second competency evaluation was not warranted. Appellant then entered an Alford plea to felony possession of methamphetamine. Appellant appealed from both convictions. The Supreme Court affirmed, holding that any alleged error in the district court’s failure to suspend proceedings and order a second competency evaluation was inconsequential. View "Marshall v. State" on Justia Law

In 2015, Mother filed a petition to terminate Father’s parental rights. The district court granted the petition, finding that Mother had proven grounds to terminate Father’s parental rights by clear and convincing evidence and that it was in the children’s best interest to do so. In so ruling, the court determined that Father had left his children in Mother’s care without provision for support and without communication for at least one year and that Father’s letters and cards to his children were incidental communications which did not prevent termination. The Supreme Court reversed, holding that the communications Father directed to his children were not merely incidental, and therefore, the requirement that there be no communication from the absent parent for a period of at least one year was not proven by clear and convincing evidence. View "RA v. AW" on Justia Law

Appellant filed a complaint for declaratory judgment and a permanent injunction against his father, his father’s wife, and a bank serving as trustee of his father’s trust (collectively, Appellees), seeking to prevent Appellees from selling the Willey Ranch, which was held in the trust. Specifically, Appellant alleged that selling the ranch amounted to a breach of contract and that his father’s wife exerted undue influence over his father to convince him to sell the ranch and to amend the trust provisions to remove Appellant from the trust. The district court granted summary judgment in favor of Appellees with respect to the breach of contract claim. The undue influence claims proceeded to trial. After a trial, the jury rejected Appellant’s undue influence claims. The Supreme Court affirmed, holding (1) the district court did not err in instructing the jury regarding the elements of undue influence; (2) the district court did not err in granting summary judgment on the breach of contract claim; and (3) Appellant’s remaining issues on appeal were either waived or not supported by cogent legal argument or pertinent authority. View "Willey v. Willey" on Justia Law

Cheyenne Newspapers, Inc. (the Tribune-Eagle) submitted a public records request to Laramie County School District Number One (the School District) asking to inspect certain school board member email communications. The School District, in response, downloaded the emails to a compact disc and made the compact disc available to the Tribune-Eagle subject to a fee for the time the School District staff spent retrieving the records. Thereafter, the Tribune-Eagle filed a declaratory judgment action seeking a ruling that the Wyoming Public Records Act does not allow the School District to charge for access to electronic records when the request is for inspection of the records and not for a copy of the records. The district court concluded, as a matter of law, that the School District was entitled to the fees it charged the Tribune-Eagle for access to the requested emails. The Supreme Court affirmed, holding that Wyo. Stat. Ann. 16-4-202(d)(i) allows a public record custodian to charge for inspection of an electronic record if the inspect request requires production of a copy of the record, and reasonableness is the limitation on the costs that may be charged a public records applicant under the statute. View "Cheyenne Newspapers, Inc., v. Board of Trustees of Laramie County School District Number One" on Justia Law

After a jury trial, Appellant was convicted of conspiracy to deliver a controlled substance. The district court sentenced Appellant to not less than four years nor more than eight years in prison. Appellant appealed, claiming that he received ineffective assistance of counsel because “a skilled criminal defense advocate would likely be able to secure a more favorable agreement than was obtained in his current sentence.” The Supreme Court affirmed, holding that Appellant failed to establish that he was prejudiced by counsel’s alleged deficient performance, and therefore, it was unnecessary to address the deficiency prong of the ineffectiveness standard. View "McNaughton v. State" on Justia Law

Horsley Company, LLC was a Florida contractor hired to install equipment at the Jackson, Wyoming airport. Cody Beazer, Horsley’s employee, was injured while he was working on the airport project. The Workers’ Safety and Compensation Division notified Horsley that it was liable to the State for all payments made to Beazer because Horsley had not filed an “employee report” for the period in which Beazer’s injury occurred. Horsley objected to the Division’s determination that it was required to reimburse the Division for payments made to Beazer. The Office of Administrative Hearings granted summary judgment for Horsley, determining that Horsley had complied with the Worker’s Compensation Act in all respects and was not liable for payments made to Beazer by the Division. The district court affirmed. The Supreme Court affirmed, holding (1) the Division’s challenge to the finding that the Division was estopped from seeking reimbursement for payments made to the claimant did not provide a sufficient basis to overturn the award of summary judgment; and (2) the Supreme Court was deprived of jurisdiction to consider the Division’s challenge to the award of attorney’s fees to Horsley. View "State ex rel. Wyoming Department of Workforce Services, Workers' Compensation Division v. Beazer" on Justia Law

After a jury trial, Defendant was convicted of attempted second-degree murder and aggravated assault and battery. The district court sentenced Defendant to forty to fifty years in prison for the attempted murder and to a term of fifteen to fifty years for the aggravated assault and battery. Defendant appealed, challenging his sentences. The Supreme Court affirmed, holding (1) the cumulative sentences Defendant received upon conviction of the offenses of attempted second-degree murder and aggravated assault and battery did not offend principles of double jeopardy; and (2) the statutes under which Defendant was convicted were not unconstitutionally vague, either on their face or as applied to the facts of Defendant’s case. View "Jones v. State" on Justia Law

Mother filed for divorce from Father. After Father failed timely to file an answer to Mother’s complaint the clerk of court entered default. Father moved to set aside the entry of default. After a hearing, which Father did not attend, the district court entered a default divorce decree. The district court denied Father’s subsequently-filed motion to set aside entry of default and default divorce decree, finding that Father received notice of the hearing on default. The Supreme Court affirmed, holding that the district court (1) did not violate Father’s due process rights when it held the default hearing on default in Father’s absence or in issuing the default divorce decree; and (2) did not abuse its discretion in its distribution of the parties’ property and debts or in its child support calculations. View "Peak v. Peak" on Justia Law

After a jury trial, Defendant was found guilty of two counts of sexual abuse of a minor in the first degree. Defendant was sentenced to serve concurrent terms of fifteen to thirty-five years in prison. Defendant appealed, asserting that the prosecutor invaded the province of the jury by telling the jurors how to deliberate in violation of his right to a fair trial. The Supreme Court affirmed, holding (1) Defendant’s claim that the prosecutor improperly told the jury what to think was without merit; and (2) thus, Defendant failed to establish prosecutorial misconduct, and the district court did not err in overruling Defendant's objection to the prosecutor’s rebuttal argument. View "Watkins v. State" on Justia Law

After a jury trial, Defendant was found guilty of conspiracy to commit first-degree murder. Defendant was sentenced to life imprisonment. The Supreme Court affirmed, holding (1) the trial court erred when it allowed the State to play a video of an explosion of a “pipe bomb” because that video was not timely provided to defense counsel, but the error was not prejudicial; (2) the trial court abused its discretion when it allowed the State to use evidence - a bank statement - that the State did not timely provide to defense counsel, but the error was harmless; and (3) the trial court did not err in admitting character evidence under Wyo. R. Evid. 404(b) and in refusing to give a limiting instruction with regard to use of Rule 404(b) evidence. View "Brown v. State" on Justia Law