Justia Wyoming Supreme Court Opinion Summaries

The State filed a petition alleging that Mother had neglected her seventeen-year-old son, NP. On January 6, 2016, Mother denied the allegations. Mother’s jury demand was due January 21, 2016. On February 5, 2016, Mother filed a motion for jury trial, contending that she had called the court’s office and the clerk of the district court within the prescribed time period to request a jury trial. The juvenile court rejected Mother’s request. After an adjudication hearing, the court adjudicated NP as neglected by Mother. The Supreme Court affirmed, holding (1) the juvenile court did not err in denying Mother’s motion for jury trial; and (2) there was sufficient evidence to support the juvenile court’s finding of neglect. View "CP v. State" on Justia Law

Mother and Father divorced pursuant to a stipulated divorce decree that granted Mother custody of the children, subject to Father’s right to liberal visitation. When Mother advised Father that she intended to move to another city with the children, Father filed a petition to modify the custody, visitation, and support provisions of the divorce decree. After a trial, the district court granted custody of the children to Father. The Supreme Court affirmed, holding (1) the district court did not err when, six months prior to trial, it granted Father temporary physical custody of the children upon offers of proof and argument, rather than after holding a full evidentiary hearing; (2) the court did not abuse its discretion by allowing the children’s counselor to testify as an expert witness at trial; (3) the district court did not abuse its discretion in awarding custody of the children to Father after a full evidentiary hearing; and (4) the court did not violate Mother’s constitutional rights to interstate travel and to associate with her children when it modified custody in favor of Father. View "Tracy v. Tracy" on Justia Law

After a jury trial, Defendant was convicted of one count of felony interference with a peace officer and of operating an ATV without liability insurance or valid registration. Defendant appealed, challenging her felony interference conviction. The Supreme Court affirmed, holding that the district court did not err in (1) denying Defendant’s motion for judgment of acquittal because the evidence was sufficient to support the conviction; (2) failing to give the jury Defendant’s proffered self-defense instructions; and (3) failing to provide the jury with definitions of phrases contained in the felony interference charge. View "Mceuen v. State" on Justia Law

In 2004, Appellant suffered a work-related injury. Appellant had shoulder surgery the next year, and the surgery was covered by the Wyoming Workers’ Compensation Division. In 2013, Appellant sought benefits for surgery on the same shoulder. During the 2013 surgery, Appellant’s surgeon found a hole in the fascia over Appellant’s acromioclavicular joint that may have occurred during the 2005 surgery. Appellant claimed that the 2013 surgery was a second compensable injury, but the Division denied her claim. On appeal, the Medical Commission concluded that there was no causal link between Appellant’s work-related injury and the need for her 2013 surgery. The district court affirmed. The Supreme Court affirmed, holding that the Commission’s conclusion that Appellant’s medical treatment was not compensable was supported by substantial evidence. View "Price v. State, ex rel., Department of Workforce Services, Workers' Compensation Division" on Justia Law

After a jury trial, Defendant was convicted of first degree murder. Defendant appealed, raising four issues related to his position at trial that the killing was not premeditated murder but, rather, the lesser included offense of voluntary manslaughter. The Supreme Court reversed due to structural error, holding that the jury instructions created reversible error as to the lesser included offense of voluntary manslaughter because they instructed the jury that the State had to prove beyond a reasonable doubt that Defendant acted in a sudden heat of passion, when the burden should have been to disprove that factor. Remanded for a new trial of the first degree murder charge. View "Shull v. State" on Justia Law

RB was injured when he and his friends were running and sliding on a patch of ice on the sidewalk between buildings at Greybull Middle School. RB sued Big Horn County School District No. 3, alleging that the school district was negligent for failing to remove the ice that had accumulated on the sidewalk. The district court granted summary judgment in favor of the school district on the question of whether there was a duty, concluding that the accumulation of ice in this case was both obvious and natural. The Supreme Court affirmed, holding that RB could not establish a prima facie case of negligence because the school district had no duty under either the natural accumulation rule or based on Greybull’s snow removal ordinance. View "RB, Jr. v. Big Horn County School District No. 3" on Justia Law

Appellee sought an order from the district court finding Appellant in contempt for violating their divorce decree by failing to pay his portion of their two children’s college tuition, expenses, and room and board. The district court entered judgment in favor of Appellee and the children. The Supreme Court affirmed in part and reversed in part, holding (1) the district court erred in entering a judgment in favor of the non-party adult children; and (2) the Court was unable to review Appellee’s claim that there was no evidence to support the district court’s judgment in favor of Appellant because Appellee did not provide an adequate record on appeal. View "Waterbury v. Waterbury" on Justia Law

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