Justia Wyoming Supreme Court Opinion Summaries

Father and Mother divorced in 2004 and agreed to share custody of their two children, Daughter and Son. In 2011, the parties stipulated to a modification of custody providing that Daughter would live with Mother permanently while Son would continue with shared custody. The court subsequently granted in part Mother’s motion for an order modifying the judgment and divorce decree by requiring Father to pay a greater amount of child support. The Supreme Court affirmed, holding (1) modification of child support was proper; and (2) the district court did not err in its calculation of Father’s child support obligation. View "Zupan v. Zupan" on Justia Law

Appellant, an inmate at Wyoming’s medium-security correctional facility in Torrington, wrote a letter to the warden asking to inspect certain public records of that institution. The institution’s employees provided him with some, but not all, of the requested documents. Appellant subsequently filed a complaint for order of enforcement and request to show cause, asserting that because the institution’s employees had not timely completed their efforts to fulfill his records requests they effectively refused to comply under the law. The institution subsequently made available to Appellant the remainder of the requested records. Thereafter, the district court dismissed Appellant’s complaint. The Supreme Court affirmed, holding that the district court (1) properly confined the scope of its review to that permitted by the Wyoming Public Records Act, (2) properly found that Appellees fully complied with Appellant’s records request, and (3) properly received information regarding the warden’s initial response to that request. Further, there was no preemption of the WPRA. View "Guy v. Lampert" on Justia Law

Plaintiff, as personal representative of the Estate of Theodore Meiners, filed an action seeking enforcement of a divorce settlement agreement entered into between Theodore and his former wife, Colleen Meiners. The district court granted summary judgment to Colleen on some claims and to Plaintiff on other claims. The district court certified its ruling as final pursuant to Wyo. R. Civ. P. 54(b). Plaintiff appealed. The Supreme Court dismissed Plaintiff’s appeal, holding that the district court’s summary judgment ruling was not properly certified as a final, appealable order pursuant to Rule 54(b). Remanded with directions. View "Meiners v. Meiners" on Justia Law

Appellant pled no contest to charges of larceny, burglary, and possession of a controlled substance with intent to deliver. Appellant later filed a motion to correct an illegal sentence, arguing that his sentence was illegal because he had not received credit for the time he spent in the county jail after he was sentenced but before he was transferred to a Wyoming Department of Corrections facility. The district court denied the motion. The Supreme Court affirmed, holding that Appellant’s claim was not one properly raised in a motion to correct an illegal sentence under Wyo. R. Crim. P. 35. View "Candelario v. State" on Justia Law

Defendant stole a car in Thermopolis and drove it toward Colorado. Defendant was arrested and jailed in Colorado. The State of Wyoming charged Defendant in Laramie County with receiving stolen property and in Hot Springs County with larceny. The State filed detainers in Colorado pursuant to the Interstate Agreement on Detainers (IAD), and Defendant requested deposition of the charges against him in both counties. Because the State failed to try Defendant within the 180-day period required by the IAD, the Laramie County charges were dismissed with prejudice. The State again failed to timely bring Defendant to trial, and the Hot Springs County charge was dismissed with prejudice. Defendant was then transported back to Colorado. The State then filed another charge against Defendant in Hot Springs County for receiving stolen property. A jury convicted Defendant. The Supreme Court reversed, holding that the dismissal of the Laramie County charge with prejudice barred the State from charging Defendant with the same crime in Hot Springs County. View "Webster v. State" on Justia Law

Mother and Father shared custody of their child pursuant to a custody order that provided for the parties to alternate custody on a weekly basis. The custody order included a drug testing requirement allowing Mother to make one request per month that Father submit to a drug test. If the test is negative, Mother must reimburse Father for the cost of the test before making another request. Father later filed a show cause motion alleging that Mother had violated the order by failing to allow him his visitation and reimburse him for a negative test. Mother filed her own show cause motion alleging that Father violated the drug testing requirement. The district court granted Father’s motion and denied Mother’s motion and ordered Mother to pay Father’s attorney fees and the costs of the negative drug test. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in finding that Father did not violate the custody order; and (2) erred in finding that Mother willfully violated the custody order, but the court’s granting of relief is nevertheless upheld because Mother’s conduct did deprive Father of visitation and reimbursement of drug testing costs to which he was entitled under the custody order. View "JLK v. MAB" on Justia Law

After a jury trial, Appellant was convicted of one count of burglary. Appellant was sentenced to eighteen to thirty-six months in prison. The Supreme Court affirmed, holding (1) Appellant failed to meet his burden of proving that he was prejudiced by the admission of what he contended was uncharged misconduct evidence; and (2) the State did not commit prosecutorial misconduct rising to the level of plain error in its closing argument, as it could not be said Defendant would have received a more favorable verdict if the comment had not been made. View "Wiese v. State" on Justia Law

Appellees, the purported owners of the “Jay Ranch,” brought an action against Appellant to establish a private road across Appellant’s property. While this suit was pending, Appellees were involved in litigation to determine the rightful ownership the Jay Ranch. The district court concluded that Appellees had satisfied the statutory threshold requirements to move forward with their private road claim and granted Appellees temporary access to the road across Appellant’s property. Thereafter, a decision was rendered against Appellees in the litigation to determine ownership of the Jay Ranch. The district court subsequently dismissed the present case for lack of prosecution. Appellant filed a motion for an award of attorney’s fees and a motion for an award of compensation for the temporary road access. The district court denied both motions. The Supreme Court dismissed Appellant’s appeal, holding (1) Appellant’s post-judgment motion for attorney’s fees was not authorized under Wyo. R. Civ. P. 54; and (2) the district court did not have jurisdiction to consider Appellant’s motion for compensation. View "Edsall v. Moore" on Justia Law

After a jury trial, Defendant was convicted of driving under the influence of alcohol. During the trial, the district court allowed the State to introduce expert testimony involving retrograde extrapolation to prove that Defendant’s blood alcohol level was above the legal limit of 0.08 percent while he was driving on the night in question. Defendant did not object to the admission of the testimony at trial. On appeal, Defendant challenged the admission of the retrograde extrapolation evidence. The Supreme Court affirmed, holding that Defendant failed to establish that he was prejudiced by admission of the challenged evidence. View "Young v. State" on Justia Law

Defendant was charged with conspiracy to deliver a controlled substance, unlawful possession of a controlled substance, and obstruction of a peace officer. Defendant filed a motion to suppress, arguing that the stop of his vehicle was unlawful. The district court denied the motion, concluding that the traffic stop and investigatory detention of Defendant were reasonable. Defendant entered a conditional guilty plea to all three charges. The Supreme Court affirmed, holding that the district court did not err when it denied Defendant’s motion to suppress evidence, as the information available to the officer at the time he made the traffic stop could give rise to a reasonable suspicion of criminal activity. View "Jennings v. State" on Justia Law