Justia Wyoming Supreme Court Opinion Summaries

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

After a one-day jury trial, Defendant was convicted of three counts of sexual abuse of a minor in the second degree. Defendant appealed, arguing that the district court abused its discretion when it admitted evidence that Defendant was in violation of his parole at the time of the offenses. The Supreme Court affirmed, holding that the district court did not abuse its discretion in admitting evidence relating to the terms of Defendant’s parole and his parole violations, as the district court considered the required Gleason criteria and had a legitimate basis for its conclusions. View "Vasquez v. State" on Justia Law

The City of Torrington brought this action seeking judgment declaring that it was authorized to set rates for electrical services it provided to customers outside the City limits and that it had discretion to utilize revenues from the provision of electricity for other City expenses. The district court (1) determined that the Public Service Commission (PSC) has the exclusive jurisdiction over the rates of the City’s electric utility service provided to customers outside the City’s corporate limits; and (2) declined to rule on the question of whether the City was properly utilizing revenues from the sale of electricity, holding that there was no justiciable controversy regarding that issue. The Supreme Court affirmed, holding (1) the applicable statutes clearly and unambiguously grant the PSC the exclusive power to set rates for electricity provided to customers outside the City corporate limits; and (2) the district court properly declined to rule on the question of the City’s expenditure of electricity revenues. View "City of Torrington v. Smith" on Justia Law

Defendant was charged with felony stalking. Defendant’s first jury trial ended in a mistrial. Thereafter, a second jury found Defendant guilty of felony stalking. Defendant was sentenced to a term of incarceration, suspended on the condition that Defendant complete five years of probation. Defendant appealed, arguing that his rights against double jeopardy were violated because the prosecutor forced him into moving for a mistrial. The Supreme Court affirmed, holding (1) there was no evidence in the record indicating prosecutorial intent to provoke the defense into moving for a mistrial; and (2) therefore, Defendant’s rights against double jeopardy were not violated in this case. View "Montoya v. State" on Justia Law