Justia Wyoming Supreme Court Opinion Summaries

Jason Thornock requested that PacifiCorp provide electric service to an irrigation pivot on his property using a particular easement. PacifiCorp did not utilize the easement that Thornock suggested but did provide electric service to the pivot using a different route under the terms of a second contract the parties entered into after the original contract. When PacifiCorp did not provide power under the easement provided for in the first contract, Thornock filed a complaint against PacifiCorp based on the alleged breach of the first contract. The district court granted summary judgment in favor of PacifiCorp. The Supreme Court affirmed, holding that the first contract between the parties had been superseded and that PacifiCorp was not required to perform under the provisions of that agreement. View "Thornock v. PacifiCorp" on Justia Law

After a jury trial, Defendant was convicted of first degree arson for setting a fire in a Walmart store. Defendant was sentenced to a term of ten to eighteen years in prison. Defendant appealed, arguing that there was insufficient evidence to support his conviction because he was intoxicated at the time he set the fire. Therefore, Defendant argued, he should have only been charged with third degree arson. The Supreme Court affirmed Defendant’s conviction and sentence, holding that the State proved that, despite Defendant’s intoxication, Defendant acted maliciously with intent to destroy or damage an occupied structure, and therefore, there was sufficient evidence to support the conviction. View "Harnden v. State" on Justia Law

After Defendant was placed on probation, the State filed a petition to revoke his probation on the grounds that Defendant violated the conditions of his probation. The district court determined that Robinson had violated the terms of his probation because he failed to prove that he maintained employment and repeatedly failed to submit to a polygraph. Defendant appealed, arguing that the district court erred in both the adjudicatory and dispositional phases of the probation revocation process. The Supreme Court affirmed the revocation and imposition of Defendant’s sentences, holding that the district court did not err either in the adjudicatory or the dispositional phases of the probation revocation process. View "Robinson v. State" on Justia Law

Appellant, a former fuel truck driver for Homax Oil Sales, Inc., was discharged from his position for unloading the incorrect fuels into tanks at various locations. Appellant applied for unemployment insurance benefits. The Department of Workforce Services, Unemployment Insurance Commission ruled that Appellant was disqualified from benefits because he was discharged for misconduct connect with his work. The district court affirmed. The Supreme Court affirmed, holding (1) serious and/or repeated negligence qualifies as misconduct under Wyoming law; and (2) substantial evidence supported the Commission’s decision that Appellant committed misconduct connected with his work. View "Clark v. State, ex rel., Dep’t of Workforce Servs., Unemployment Ins. Comm’n" on Justia Law

Child was born to Mother and Father in 2003. Within the next year, Mother’s current husband came into her and her son’s life. In 2015, Mother filed a petition to change Child’s surname to Sowers-Collision. The district court denied the petition, ruling that changing Child’s surname would be detrimental to Father’s interests under Wyo. Stat. Ann. 1-25-101. Mother appealed, arguing that the district court erred by failing to consider the best interest of Child when it denied her petition. The Supreme Court affirmed, holding that because the state of the record in this case made it impossible to determine whether the district court in fact considered the best interest of the child, the Court could not conclude that the district court failed to consider the question. View "Sowers-Collison v. Hansley" on Justia Law

Appellant fractured his right hip when, during the course of his employment, he climbed from the bed of a dump truck and fell onto a rock. After surgery was performed on the hip, Appellant had constant pain in both hips and finally had a total hip replacement. After his hip replacement, Appellant was pigeon-toed. Appellant was later in an automobile accident that resulted in injuries. Appellant sought worker’s compensation benefits for the injuries sustained in the automobile accident, claiming that, due to his work-related hip injury, his foot was not functioning properly and slipped off the brake pedal and got stuck between the brake and gas pedals. The Office of Administrative Hearings (OAH) denied Appellant’s worker’s compensation claim, finding that Appellant failed to prove a causal relationship between his automobile accident and his prior work-related accident. The Supreme Court affirmed, holding (1) the OAH properly applied the second compensable injury rule; and (2) the OAH’s reasonably concluded that Appellant had not established by a preponderance of the evidence that his automobile accident was casually connected to his original work-related injury. View "Jensen v. State, ex rel., Dep’t of Workforce Servs., Workers' Comp. Div." on Justia Law

After a jury trial, Defendant was convicted of seven counts of felony forgery and one count of misdemeanor theft. Defendant appealed, alleging that her prosecution was motivated by prosecutorial vindictiveness, that she received ineffective assistance of counsel, that the prosecutor argued facts not in evidence during closing arguments, that the district court erred by failing to provide supplemental instructions to the jury, and that the evidence was insufficient to support the convictions. The Supreme Court affirmed, holding (1) there was no plain error in Defendant’s claim of vindictive prosecution, in Defendant’s claim of prosecutorial misconduct, or in the district court’s refusal to provide supplemental instructions to the jury; (2) Defendant’s right to effective assistance of counsel was not violated; and (3) Defendant’s convictions were supported by sufficient evidence. View "Mraz v. State" on Justia Law

Jim Hipner, LLC (Hipner), a trucking company, obtained an umbrella policy from Century Surety Company (Century) that contained a notice provision stating that the insured will notify Century “as soon as practicable” of an occurrence, offense, or injury. When one of Hipner’s drivers produced a multi-vehicle collision (the accident) that resulted in a serious injury, Century filed suit in federal court seeking a declaratory judgment that it did not have an obligation to defend or indemnify Hipner in connection with any claims relating to the accident because Hipner failed to provide written notice “as soon as practicable.” The district court concluded that Century received timely notice under the policy as a matter of Wyoming law. Century appealed, and the United States Court of Appeals for the Eighth Circuit certified a question to the Wyoming Supreme Court regarding the enforceability of the insurance policy notice provision. The Supreme Court answered that, under Wyoming law and regardless of the express language of the insurance policy, an insurer must be prejudiced before being entitled to deny coverage when the insured has failed to give notice “as soon as practicable.” View "Century Surety Co. v. Jim Hipner, LLC" on Justia Law

In 2013, William Rogers was working for Russell Construction Company (Russell) when he claimed to have fallen against a ledge of old concrete. In 2014, the Workers' Compensation Division issued a determination that Rogers had suffered a compensable injury. Russell objected to that determination, arguing that the claim was fraudulent. A hearing officer with the Office of Administrative Hearing denied Rogers’s claim for worker’s compensation benefits, concluding that Rogers had not proved that he suffered a compensable injury in 2013. The district court affirmed. The Supreme Court affirmed, holding that the hearing examiner’s determinations of fact were reasonable and based on substantial evidence. View "Rogers v. Russell Constr. Co., Inc." on Justia Law

Petitioner was discharged from her position as high school principal of the St. Stephens Indian School for “not promptly assessing a student who was potentially intoxicated and allowing the student to remain in class while [Petitioner] left the building.” Petitioner applied for unemployment insurance benefits. A deputy for the Unemployment Insurance Division denied Petitioner’s claim, determining that she was discharged for misconduct connected with her work. On appeal, a hearing officer ruled that Petitioner was discharged from her unemployment but not for misconduct connected with her work. The Department of Workforce Services, Unemployment Insurance Commission reversed. The district court reversed, ruling that the Commission’s decision was not supported by substantial evidence. The Supreme Court affirmed, holding that the record did not support a conclusion that Petitioner’s action was anything more than ordinary negligence or a good faith error in judgment. View "State ex rel., Dep’t of Workforce Servs., Unemployment Ins. Comm’n v. Kinneman" on Justia Law