Justia Wyoming Supreme Court Opinion Summaries

After a four-day jury trial, Defendant was found guilty of multiple counts of first degree sexual assault, battery, and unlawful contact without bodily injury. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress statements he made to a nurse during a sexual assault examination in an alleged violation of Defendant’s rights under Miranda v. Arizona; and (2) Defendant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48(b) and the Sixth Amendment to the United States Constitution. View "Tate v. State" on Justia Law

Walker Inman executed an inter vivos trust and a last will and testament. After Mr. Inman died, Daralee Inman, his wife, petitioned the district court for probate of Mr. Inman’s estate. Two years after the probate was opened, Wyoming Trust Company (WTC) filed a petition seeking to be appointed as the conservator of the minor children in the probate action. The district court granted the petition. WTC, as conservator for the minor children, filed a separate complaint for declaratory relief and damages, together with a petition to remove trustees, alleging six causes of action. The cases proceeded simultaneously over the next two years. The district court later ordered the cases consolidated. The court then issued its decision and order, interpreting a trust provision and holding that the Wyoming Probate Code governs the transfer of property to the trust but making no final determination of either of the two consolidated matters. Daralee Inman appealed. The Supreme Court dismissed the appeal, holding that the Court lacked jurisdiction to decide the appeal because the order was not a final appealable order. View "In re Estate of Inman" on Justia Law

Defendant was sentenced to two life sentences according to law for crimes he committed in the 1990s. In 2015, Defendant filed a complaint against the Wyoming Board of Parole and the Wyoming Department of Corrections pursuant to the Declaratory Judgment Act, alleging various constitutional violations. The district court dismissed Defendant’s claims. The Supreme Court affirmed, holding (1) Wyo. Stat. Ann. 7-16-2016(a)(i) does not violate Defendant’s equal protection rights because there is a legitimate state interest in treating prisoners differently with respect to the statute; (2) the Wyoming Department of Corrections’ good time policy does not violate Defendant’s equal protection rights because prisoners serving life according to law and prisoners serving a term of years sentence are not similarly situated; (3) the enactment of section 7-16-205(a)(i) did not impliedly repeal Wyo. Stat. Ann. 7-13-402(a); (4) the Wyoming Board of Parole did not violate the doctrine of separation of powers by enacting policies governing the commutation application procedure; (5) Defendant’s due process rights were not violated by the amendment to the commutation application procedure; and (6) the Wyoming Board of Parole’s amendment to the commutation application procedure did not violate Defendant’s constitutional protection against ex post facto laws. View "Bird v. Wyoming Board of Parole" on Justia Law

SO was in the legal custody of the Wyoming Department of Family Services and had been in the physical care of Foster Parents since she was three days old. The grandmother and step-grandfather of SO (together, Grandparents) filed a motion seeking to transfer placement of SO from Foster Parents to Grandparents. The juvenile court denied the motion and ordered that SO should continue to be placed with Foster Parents, determining that it was in the best interests of SO to remain in the custody of Foster Parents. The Supreme Court affirmed, holding that the juvenile court did not abuse its discretion by denying Grandparents’ motion to place SO with them. View "In re SO" on Justia Law

Father and Mother, who never married but had a son, stipulated to an order setting custody and visitation. This opinion inferred from the information that Father was the custodial parent and that Mother had defined visitation. A year and a half after the stipulated order was entered, Father filed a “Petition to Modify Visitation and Motion for Contempt and Restraining Order,” asserting that a material change in circumstances occurred and seeking to have Mother held in contempt for failing to pay child support. The district court denied the petition to modify and granted the motion for contempt. The Supreme Court affirmed, holding that the district court did not abuse its discretion by (1) denying Father’s petition to modify Mother’s visitation after finding that there was no material change in circumstances, and (2) conducting the modification hearing as it did. View "ELA v. AAB" on Justia Law

After a jury trial, Appellant was found guilty of stalking. The district court sentenced Appellant to a term of three to five years in prison. Appellant appealed, arguing that the district court abused its discretion by not granting a mistrial for a violation of an order in limine concerning Wyo. R. Evid. 404(b) evidence and by imposing a discovery sanction that precluded the State from introducing untimely disclosed text messages but allowing the jury to hear testimony about them. The Supreme Court affirmed, holding that the district court did not err in not granting a mistrial and in not imposing a stiffer sanction for the discovery violation. View "Salinas v. State" on Justia Law

Plaintiffs, the purchasers of a health claims administration company, brought a breach of contract action against Defendant, the seller. After learning that they had not acquired all of the assets that contracted to purchase, Plaintiffs continued to operate the business for the next eighteen months. Only then did they stop making payments on the promissory note and then file this action. Defendant counterclaimed for breach of contract. Plaintiffs raised the affirmative defense that Defendant was first to breach the contract and that Plaintiffs were therefore excused from performing their contractual duties. The district court entered judgment in favor of Defendant. The Supreme Court affirmed, holding that Plaintiffs’ conduct after learning of Defendant’s alleged breach precluded it from asserting a prior breach as a defense to Plaintiffs’ breach-of-contract claim. View "Maverick Benefit Advisors, LLC v. Bostrom" on Justia Law

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