Justia Wyoming Supreme Court Opinion Summaries

Defendant entered a conditional plea to a fourth offense felony DWUI charge, reserving the right to challenge the denial of his motion to dismiss. The court found Defendant guilty of his fourth DWUI offense in a ten-year period and sentenced him to two to four years, suspended in favor of supervised probation. Defendant appealed, arguing that his 2005 conviction could not be used as a prior offense because it did not occur within ten years of his present conditional guilty plea. The Supreme Court affirmed, holding that the ten-year look-back period for enhanced DWUI penalties applies from the date of the last offense, rather than the date of the last conviction. View "Ramirez v. State" on Justia Law

In anticipation of receiving the recommendations of a staffing and compensation study conducted by the City of Cheyenne’s contractor, the City created the Employee Investment Study Implementation Team (EIS Team). The EIS Team was created to consider alternative means of implementing those recommendation. Before the EIS Team met, the Wyoming Tribune-Eagle, a newspaper, filed a petition for a declaratory judgment that the EIS Team must conduct its meetings in public, as required by the Wyoming Public Meetings Act. The district court granted summary judgment for the City, concluding that the EIS Team was not an “agency” as defined by the Act, and therefore, the EIS Team was not subject to the Act’s open meetings requirements. The Supreme Court affirmed, holding that the EIS Team was not subject to the Act because, although it was a committee, it was not created pursuant to Wyoming constitution, statute, or ordinance. View "Cheyenne Newspapers, Inc. v. City of Cheyenne" on Justia Law

Bud Federer, who died in 2003, enjoyed a successful career as a businessman in Wyoming. In 2011, Margie, Bud's wife, moved to an assisted living facility. During Bud’s life and after he died, the family created numerous entities to hold and manage their business interests and to pass Bud and Margie’s estate to their three daughters. The sisters, however, disagreed about money, and those disagreements led to accusations of misconduct and breaches of the duties that attached to their roles as trustees and LLC managers. The sisters engaged in litigation involving claims, counterclaims, and cross-claims. The district court sorted out these claims after a bench trial. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the district court’s conclusion that Dino Moncecchi did not breach his fiduciary duties to an LLC was not clearly erroneous; (2) the removal of Rebecca Shwen as trustee of the Margie Jean Federer Revocable Trust was not based on findings that were clearly erroneous; (3) the district court incorrectly applied the burden of proof for establishing damages resulting from Rebecca’s breach of fiduciary duty; and (4) the district court did not abuse its discretion when it awarded attorney fees against Rebecca for filing a frivolous claim. View "Acorn v. Moncecchi" on Justia Law

Nikki Jo Burtsfield died in a law enforcement shooting. The county coroner examined the body and prepared the verdict and case docket, listing the manner and cause of death. Appellant filed a public records request with the coroner seeking disclosure of the verdict and case docket. Dissatisfied with the documents he received in response to his request, Appellant filed a “Motion for Reasonable Response” with the district court, requesting that the court order the coroner to produce a case docket of “sufficient detail.” The district court dismissed the action pursuant to Wyo. R. Civ. P. 12(c). The Supreme Court affirmed, holding (1) Appellant was actually requesting relief in mandamus, and even though he did not follow the pleading requirements, the district court had jurisdiction over the action; and (2) on the merits, while the district court erred in denominating its decision as a dismissal under Rule 12(c) rather than a summary judgment, its decision was correct because the coroner did not have an absolute, clear and indisputable duty to provide the detailed information requested by Appellant. View "Williams v. Sundstrom" on Justia Law

Prior to his death, Timothy Trefren owned Trefren Construction and operated it as a sole proprietorship. Trefren Construction filed a complaint against V&R Construction, LLC and Cocca Development, Ltd. (collectively, Defendants) for breach of contract. Defendants filed a motion to dismiss, asserting that all corporations associated with the name Trefren Construction were inactive or had been dissolved. Thereafter, Trefren filed a motion for substitution of party seeking to substitute the Estate of Timothy Trefren in the stead of Trefren. The district court denied the motion for substitution of party and dismissed the complaint for lack of subject matter jurisdiction because the named plaintiff was not the real party in interest. The court then made an additional ruling that Defendants were entitled to judgment as a matter of law because the parties’ contracts were voidable. The Supreme Court reversed, holding (1) the real party in interest requirement is not jurisdictional, and therefore, dismissal of Trefren Construction’s complaint was not mandated; (2) the district court abused its discretion when it denied Trefren Construction’s motion to substitute the Estate as the real party in interest; and (3) the district court’s summary judgment ruling was procedurally infirm and unsupported by a showing of undisputed facts. View "Trefren Construction Co. v. V&R Construction, LLC" on Justia Law

In 2014, Tana Brown filed a complaint seeking a divorce from Darold Brown. Six days later, the district court signed a proposed stipulated decree of divorce. Ten months later, Tana moved to vacate or modify the divorce decree. After trial was scheduled, a scheduling conference was held and resulted in the entry of a scheduling order. Tana then filed a motion for sanctions asserting that Darold had not complied with a deadline in the scheduling order. The district court granted the motion for sanctions, imposing the requested sanction of prohibiting Darold from presenting witness testimony or exhibits at trial. After a trial, the district court granted physical custody of the parties’ children to Tana and divided remaining property and debt. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in imposing sanctions. View "Brown v. Brown" on Justia Law

Jackman Construction, Inc. (Jackman) was the successful bidder on a project to install new water lines and a pump station for the City of Green River. Rock Springs Winnelson Co. (Winnelson) supplied materials for the project. Jackman eventually stopped paying Winnelson’s invoices, and Winnelson refused to provide any more materials. Winnelson filed suit against Jackman for its failure to pay invoices totaling $21,705, which included principal and service charges. Jackman counterclaimed for, inter alia, breach of contract and promissory estoppel. The district court granted judgment in favor of Winnelson on the outstanding principal, denied Winnelson’s claim for unpaid service charges, and denied Jackman’s counterclaims. The Supreme Court affirmed, holding (1) the district court erred in refusing to accept the parties’ stipulation as to the amount Jackman paid Winnelson, but the error was harmless; (2) the district court did not err in the remainder of its judgment; and (3) sanctions were not warranted. View "Jackman Construction, Inc. v. Rock Springs Winnelson Co." on Justia Law

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