Justia Wyoming Supreme Court Opinion Summaries

Appellant was discharged from his position as a firefighter with the City of Laramie after random breathalyzer tests performed while he was on duty detected alcohol in his system. The Civil Service Commission reduced Appellant’s discipline from discharge to a suspension. The district court reversed and remanded for further agency proceedings, concluding that the Commission had applied the wrong legal standard. On remand, the Commission found that the breathalyzer tests were invalid and ruled in favor of Appellant. The district court again reversed on remanded, concluding that the law and the record did not support the Commission’s conclusion. On remand, the Commission consented to Appellant’s discharge. The district court dismissed Appellant’s petition for review. The Supreme Court dismissed Appellant’s appeal, holding (1) the district court did not have subject matter jurisdiction to consider the City’s petition for review of the Commission’s second decision because the legislature did not grant cities the right to judicial review of commission decisions refusing to consent to employee discharges; and (2) because the district court lacked jurisdiction to review the Commission’s second decision, it was final, and all of the proceedings that followed the Commission’s second decision were improper. View "Vance v. City of Laramie" on Justia Law

Appellant suffered a work-related neck injury. The Wyoming Workers’ Safety and Compensation Division awarded Appellant benefits related to that injury and paid his associated medical bills. In 2011, Appellant began experiencing black outs, known as “syncope,” which he attributed to treatment of his neck injury. After Appellant fell during a syncope event, he sought approval from the Division for lower back surgery to treat an injury he received during the fall. The Division denied approval. The Medical Commission upheld the denial, and the district court affirmed. The Supreme Court affirmed, holding (1) the Commission did not act arbitrarily and capriciously when it denied Appellant benefits after determining that the benefits requested for injuries sustained during a syncope event were unrelated to Appellant’s workplace injury; and (2) the fact that the Division previously paid uncontested medical claims related to Appellant’s syncope did not preclude the Division from contesting the causation of the black outs for purposes of future benefits. View "Hood v. State, ex rel. Department of Workforce Services" on Justia Law

In 2005, the district court appointed Brenda Clark as the guardian of MKH, who was born not long after the appointment. In 2006, the court extended the guardianship. In 2014, Father filed a petition seeking to vacate the 2005 order. Father then filed a motion to dismiss for lack of subject matter jurisdiction, arguing that the district court did not have jurisdiction to enter its 2005 order appointing Clark as MKH’s guardian because MKH was not yet born. The district court entered an order granting Father’s motion to dismiss for lack of jurisdiction and declared the 2005 and 2006 orders void. The Supreme Court reversed, holding (1) a court may not appoint a guardian for an unborn child; but (2) the 2005 order appointing a guardian did not rise to the level of a jurisdictional defect. View "Clark v. Huffer" on Justia Law

After a four-day jury trial, Defendant was found guilty of multiple counts of first degree sexual assault, battery, and unlawful contact without bodily injury. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress statements he made to a nurse during a sexual assault examination in an alleged violation of Defendant’s rights under Miranda v. Arizona; and (2) Defendant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48(b) and the Sixth Amendment to the United States Constitution. View "Tate v. State" on Justia Law

Walker Inman executed an inter vivos trust and a last will and testament. After Mr. Inman died, Daralee Inman, his wife, petitioned the district court for probate of Mr. Inman’s estate. Two years after the probate was opened, Wyoming Trust Company (WTC) filed a petition seeking to be appointed as the conservator of the minor children in the probate action. The district court granted the petition. WTC, as conservator for the minor children, filed a separate complaint for declaratory relief and damages, together with a petition to remove trustees, alleging six causes of action. The cases proceeded simultaneously over the next two years. The district court later ordered the cases consolidated. The court then issued its decision and order, interpreting a trust provision and holding that the Wyoming Probate Code governs the transfer of property to the trust but making no final determination of either of the two consolidated matters. Daralee Inman appealed. The Supreme Court dismissed the appeal, holding that the Court lacked jurisdiction to decide the appeal because the order was not a final appealable order. View "In re Estate of Inman" on Justia Law

Defendant was sentenced to two life sentences according to law for crimes he committed in the 1990s. In 2015, Defendant filed a complaint against the Wyoming Board of Parole and the Wyoming Department of Corrections pursuant to the Declaratory Judgment Act, alleging various constitutional violations. The district court dismissed Defendant’s claims. The Supreme Court affirmed, holding (1) Wyo. Stat. Ann. 7-16-2016(a)(i) does not violate Defendant’s equal protection rights because there is a legitimate state interest in treating prisoners differently with respect to the statute; (2) the Wyoming Department of Corrections’ good time policy does not violate Defendant’s equal protection rights because prisoners serving life according to law and prisoners serving a term of years sentence are not similarly situated; (3) the enactment of section 7-16-205(a)(i) did not impliedly repeal Wyo. Stat. Ann. 7-13-402(a); (4) the Wyoming Board of Parole did not violate the doctrine of separation of powers by enacting policies governing the commutation application procedure; (5) Defendant’s due process rights were not violated by the amendment to the commutation application procedure; and (6) the Wyoming Board of Parole’s amendment to the commutation application procedure did not violate Defendant’s constitutional protection against ex post facto laws. View "Bird v. Wyoming Board of Parole" on Justia Law

SO was in the legal custody of the Wyoming Department of Family Services and had been in the physical care of Foster Parents since she was three days old. The grandmother and step-grandfather of SO (together, Grandparents) filed a motion seeking to transfer placement of SO from Foster Parents to Grandparents. The juvenile court denied the motion and ordered that SO should continue to be placed with Foster Parents, determining that it was in the best interests of SO to remain in the custody of Foster Parents. The Supreme Court affirmed, holding that the juvenile court did not abuse its discretion by denying Grandparents’ motion to place SO with them. View "In re SO" on Justia Law

Father and Mother, who never married but had a son, stipulated to an order setting custody and visitation. This opinion inferred from the information that Father was the custodial parent and that Mother had defined visitation. A year and a half after the stipulated order was entered, Father filed a “Petition to Modify Visitation and Motion for Contempt and Restraining Order,” asserting that a material change in circumstances occurred and seeking to have Mother held in contempt for failing to pay child support. The district court denied the petition to modify and granted the motion for contempt. The Supreme Court affirmed, holding that the district court did not abuse its discretion by (1) denying Father’s petition to modify Mother’s visitation after finding that there was no material change in circumstances, and (2) conducting the modification hearing as it did. View "ELA v. AAB" on Justia Law

After a jury trial, Appellant was found guilty of stalking. The district court sentenced Appellant to a term of three to five years in prison. Appellant appealed, arguing that the district court abused its discretion by not granting a mistrial for a violation of an order in limine concerning Wyo. R. Evid. 404(b) evidence and by imposing a discovery sanction that precluded the State from introducing untimely disclosed text messages but allowing the jury to hear testimony about them. The Supreme Court affirmed, holding that the district court did not err in not granting a mistrial and in not imposing a stiffer sanction for the discovery violation. View "Salinas v. State" on Justia Law

Plaintiffs, the purchasers of a health claims administration company, brought a breach of contract action against Defendant, the seller. After learning that they had not acquired all of the assets that contracted to purchase, Plaintiffs continued to operate the business for the next eighteen months. Only then did they stop making payments on the promissory note and then file this action. Defendant counterclaimed for breach of contract. Plaintiffs raised the affirmative defense that Defendant was first to breach the contract and that Plaintiffs were therefore excused from performing their contractual duties. The district court entered judgment in favor of Defendant. The Supreme Court affirmed, holding that Plaintiffs’ conduct after learning of Defendant’s alleged breach precluded it from asserting a prior breach as a defense to Plaintiffs’ breach-of-contract claim. View "Maverick Benefit Advisors, LLC v. Bostrom" on Justia Law