Justia Wyoming Supreme Court Opinion Summaries

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

Appellant Mary Leib sought benefits from the Wyoming Workers’ Compensation Division after she developed abscesses in her breasts. Leib was employed as a maintenance worker for Laramie County Community College in Cheyenne. She began working on the grounds of the College in April 2012. As part of her duties as a groundskeeper, Leib was required to work with dirt that was mixed with untreated manure from livestock kept on campus and from traveling circus animals. In June 2012, approximately two weeks after she began planting flowers using the dirt and manure mixture, Leib experienced pain and swelling in both of her breasts. She sought treatment at the emergency room, where she was diagnosed with mastitis. Upon returning to work, the swelling developed again. The second time she sought treatment, her surgical incisions split open. Subsequent cultures indicated that several different types of peptostreptococcus bacteria were present. The Division denied the claim. The Medical Commission upheld the Division’s determination after finding that she had not met her burden of proving that her condition was related to her employment. Leib appealed to the district court, which affirmed the Medical Commission’s order. She challenged the district court’s decision in this appeal. Finding no reversible error, the Supreme Court affirmed. View "In the Matter of the Worker's Compensation Claim of: Leib v. Wyoming, ex rel., Department of Workforce Services, Workers' Compensation Division" on Justia Law

Appellant Jeffery Lafferty was incarcerated awaiting trial for 811 days before pleading guilty to two counts of taking indecent liberties with his minor stepdaughter. After balancing the required factors, the district court concluded that the delay in bringing Lafferty to trial was reasonable and did not impair his right to a fair trial. On appeal, he argued his constitutional right to a speedy trial was violated. A review of the record revealed to the Wyoming Supreme Court that much of the delay was the result of appellant's own actions, "which in the aggregate caused his case to go on the circuitous journey it did." As such, the Court found no violation of appellant's constitutional right to a speedy trial and affirmed his convictions. View "Lafferty v. Wyoming" on Justia Law

Alfred and Pegge Cooksley placed their ranch and other property in a revocable charitable trust (Trust) that named Shriners Hospitals for Children and the Kalif Children’s Travel Fund as beneficiaries and First Northern Bank of Wyoming as the successor trustee. The year 2100 was specified as the Trust’s termination date. After Pegge and Jack died, Shriners filed a petition seeking termination of the Trust and an immediate distribution of the Trust assets. Shriners separately filed a complaint against First Northern Bank alleging that it had breached its fiduciary duty to the Trust beneficiaries. The district court ruled against Shriners and directed Shriners to pay First Northern Bank its attorney fees and costs. The Supreme Court affirmed, holding (1) the district court did not err in ruling that the Trust does not violate the rule against perpetuities; and (2) the district court did not err in denying Shriners’ claims against First Northern Bank and awarding attorney fees and costs. View "Shriners Hosps. for Children v. First N. Bank of Wyoming" on Justia Law