Justia Wyoming Supreme Court Opinion Summaries

In 1995, Appellant pled guilty to second-degree murder and was sentenced to twenty-eight years to life. In 2015, Appellant filed a pro se motion to correct an illegal sentence, claiming that his sentence was illegal because the district court failed to provide a firearms disqualification advisement at the time of sentencing. The district court denied the motion, concluding (1) the advisement statute, Wyo. Stat. Ann. 7-11-507, was not applicable to Appellant’s case because the statute was not enacted until 2009; and (2) Appellant’s sentence was permitted under Wyo. Stat. Ann. 6-2-104. Appellant appealed, presenting several claims in support of his contention that his sentence was illegal. The Supreme Court affirmed, holding that the district court did not err in its decision to deny Appellant’s motion to correct illegal sentence. View "Barela v. State" on Justia Law

Appellants, the owners of a tract of land in the Riva Ridge subdivision, submitted their plans to build a home and writer’s studio to the Riva Ridge Owners Association’s Site Committee. The Site Committee rejected the plans on the basis that some of Appellants’ home would be visible from some locations in other homes. Appellants filed a complaint against the Association and others (collectively, Appellees) alleging several causes of action. Appellants filed a separate complaint requesting a determination of the term “principal residence site” in the covenants. The district court granted summary judgment for Appellees on several issues. After a trial, the district court interpreted the phrase “principal residence site” in a way that required complete invisibility between the homes in the subdivision. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) erred in its interpretation of the phrase “principal residence,” as the covenants only require that a principal residence be invisible only from a precise area of land on each tract; (2) erred in granting summary judgment on Appellants’ breach of contract and bad faith claims; and (3) properly determined that Appellants must seek permission from the Site Committee before planting any trees on their tract. View "Felix Felicis, LLC v. Riva Ridge Owners Ass’n" on Justia Law

After a jury trial, Defendant was convicted of possessing small amounts of morphine and methamphetamine. The offenses were felonies due to Defendant’s prior controlled substance convictions. The district court sentenced Defendant to concurrent sentences of two to five years in prison. The Supreme Court affirmed the convictions and sentence, holding (1) Defendant’s counsel was not ineffective for failing to move to suppress the evidence found during the warrantless search of Defendant’s backpack; (2) the evidence was sufficient to support Defendant’s convictions; and (3) the district court properly rejected Defendant’s request for an additional instruction on constructive possession. View "Lemley v. State" on Justia Law

Jason and Tracy Thornock (together, Plaintiffs), who owned a ranch in Lincoln County, filed a complaint against neighboring landowners (Defendants), alleging that their property was landlocked and requesting establishment of a private road. After a bench trial, the district court denied the complaint, concluding that Plaintiffs failed to establish the necessity for a private road because they did not prove that their property was landlocked or that their access was substantially inconvenient. The Supreme Court affirmed, holding that the district court did not err in finding that Plaintiffs failed to establish the need for a private road because the record showed that Plaintiffs had direct access to their property via a public road that provided convenient and reasonable access. View "Thornock v. Esterholdt" on Justia Law

After a jury trial, Defendant was convicted of one count child endangering/obscene act. The conviction arose from Defendant’s act of exposing himself to an eleven-year-old girl and then masturbating. Defendant appealed, arguing (1) the trial court erred when it refused to instruct the jury on the definition of the term “presence” as it is used in the charging statute, Wyo. Stat. Ann. 6-4-403(b)(iii), and (2) the district court improperly admitted evidence of Defendant’s prior bad acts in the form of court documents rather than testimony. The Supreme Court reversed, holding (1) the trial court did not err in refusing to admit the proposed jury instruction; but (2) the trial court abused its discretion when it admitted the court documents to show prior bad acts evidence, and Defendant was prejudiced by the admission of those exhibits. Remanded for a new trial. View "Dougherty v. State" on Justia Law

The City of Laramie fired Bret Vance, an employee of the City’s Fire Department, after Wyomed Laboratory, Inc. conducted a breathalyzer test on Vance that indicated the presence of alcohol. Vance filed suit against Wyomed, alleging that Wyomed negligently failed to maintain its testing equipment, negligently failed to train employees on equipment maintenance, and negligently misrepresented that the test results were reliable and accurate. The district court granted Wyomed’s motion to dismiss, concluding that Vance’s claims were barred by the applicable statute of limitations. The Supreme Court affirmed, holding that Vance failed to bring his claims within the time prescribed by the relevant statute of limitations. View "Vance v. Wyomed Lab., Inc." on Justia Law

Contractor Anderson Carpentry and Construction built a home for Shad and Trisha Bates. Anderson contracted with Century Lumber Center to purchase supplies and materials to build the Bates home. The Bates paid Anderson for materials used on the home, but those funds were applied to other accounts, and the account with Century on the Bates job became delinquent. Century filed a material lien against the Bates property and filed a complaint seeking to foreclose the lien against the property. The district court ultimately enforced the lien. The Supreme Court reversed, holding that the lien was not timely filed as a matter of law. View "Bates v. Chicago Lumber Co. of Omaha" on Justia Law

Appellant Justin Sadler was convicted by jury of aggravated assault. Prior to his state trial, Sadler was convicted in federal court of being a felon in possession of a firearm, based on the same circumstances that gave rise to his state charges. The State indicated that it would seek to admit this prior conviction under W.R.E. 609(b) if Sadler testified. The district court reserved ruling on whether Sadler’s federal conviction would be admissible, however, it observed that if Sadler denied possessing the firearm, the probative value of the prior conviction “escalates off the charts.” Sadler elected not to testify at trial. On appeal of his state charges, Sadler challenged the propriety of the district court’s comments, claiming that the court improperly chilled the exercise of his constitutional right to defend himself by testifying on his own behalf. Because he did not preserve the issue he raised on appeal, the Wyoming Supreme Court affirmed. View "Sadler v. Wyoming" on Justia Law

Appellant Marvin Clay challenged the denial of his motion to suppress evidence supporting a conviction for driving under the influence of alcohol. The officer testified that he made the stop because the car did not have any license plates displayed. All he could see at that point was a white piece of paper in the upper left corner of the rear window, which was heavily tinted. Because he was unable to verify that the white piece of paper was a document which would allow Appellant to operate the vehicle temporarily, the officer approached the car and talked to him. He asked about the paper and if there was a bill of sale. The document in the window turned out to be a title, but more than forty-five days had elapsed since the transfer, and the officer could not tell if it was notarized, both of which were required for operation of the vehicle to be legal. Appellant said there was a bill of sale, and opened his wallet and started thumbing through it for that document, but he never pulled anything out. Appellant could not provide a driver’s license or proof of insurance either. Within the first minute of Appellant slowly flipping through his wallet, the officer observed signs of possible intoxication. A DUI Task Force officer was called, and three field sobriety tests were performed. Appellant "performed poorly" on all three. Appellant was ultimately charged, inter alia, with Driving Under the Influence, Fourth Offense. On appeal, Appellant argued that his detention was improperly expanded beyond the scope of the initial traffic stop, and that the evidence used to support the DUI arrest was discovered only after the unnecessary contact and therefore ought to have been suppressed. Finding no error in the trial court's decision, the Supreme Court affirmed. View "Clay v. Wyoming" on Justia Law

Three consolidated cases involved an ongoing dispute over personal property awarded to Megan Golden in her 2012 divorce from Todd Guion. Golden appealed the district court’s order that: (1) rejected her request for a rehearing on a 2012 denial of her motion to find Guion in contempt of court; (2) denied her motion to vacate a February 2015 order following contempt hearings; and (3) granted Guion’s request for sanctions under W.R.C.P. 11. After review, the Supreme Court dismissed two of the cases for lack of jurisdiction, and affirmed the sanctions case because Golden did not file not file timely notices of appeal. View "Golden v. Guion" on Justia Law