Justia Wyoming Supreme Court Opinion Summaries

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Defendant entered into a plea agreement pursuant to which Defendant agreed to plead guilty to third degree sexual assault in exchange for a deferred prosecution and a five-year supervised probation. After Defendant had served nearly four years of probation, the district court modified the terms of her probation to require that she submit to and pay for a psycho-sexual evaluation. Defendant appealed, arguing that the district court improperly modified the conditions of her probation where there was no showing of a change in circumstances and no evidence presented to establish the need for the psychosexual evaluation in this case. The Supreme Court affirmed, holding (1) a sentencing court is not specifically required to find a change in circumstances before entering a modification order; and (2) under the circumstances of this case, the district court’s modification was not an abuse of discretion. View "Harada v. State" on Justia Law

Posted in: Criminal Law
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Charley Collins and his son, Brett, were both employed by COP Wyoming, LLC. Roger Ross, a job superintendent, was operating a track hoe when he struck Brett in the head, severely injuring him. Brett died from his injuries. Charley sued COP Wyoming and Ross, alleging that he suffered emotional injuries after he witnessed his son’s death. The district court concluded that Charley’s claims were derivative of the covered death of the son and were therefore barred by worker’s compensation immunity. The Supreme Court reversed, holding that Charley’s claim for emotional injury is based upon a duty to him that is independent of the covered death of his son and is not barred by worker’s compensation immunity. View "Collins v. COP Wyoming, LLC" on Justia Law

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At the heart of these three consolidated appeals was Sky Harbor’s alleged failure to pay rent to the Cheyenne Regional Airport and to leave the Airport premises. Sky Harbor argued that the district court lacked subject matter jurisdiction to decide any of the cases now on appeal. The district court generally ruled in favor of the Airport in all three cases. The Supreme Court affirmed, holding (1) the district and circuit courts did not lack subject matter jurisdiction in the three combined appeals; and (2) the judgments were entered in accordance with the law. View "Sky Harbor Air Serv., Inc. v. Cheyenne Reg’l Airport Bd." on Justia Law

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After a jury trial, Defendant was found guilty of four counts of first degree sexual abuse involving two minors. Defendant was sentenced to life in prison without the possibility of parole. The Supreme Court affirmed, holding (1) the district court did not err by (i) rejecting Defendant’s ineffective assistance of counsel claim, (ii) determining that the child witnesses were competent to testify, (iii) denying Defendant’s requests for continuances, and (iv) admitting other bad acts evidence under Wyo. R. Evid. 404(b); (2) the district court erred in allowing the admission of some hearsay testimony at trial, but the errors were harmless; and (3) Defendant’s constitutional right to a speedy trial was not violated. View "Griggs v. State" on Justia Law

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Pursuant to a plea agreement, Defendant pled guilty to one count of first-degree sexual abuse of a minor. Defendant later filed a motion for sentence modification or reduction under newly discovered evidence arguing that his guilty plea was involuntary and that his trial counsel provided ineffective assistance. The district court construed the motion as both a motion to withdraw Defendant’s guilty plea and to reduce Defendant’s sentence. The district court denied the request to withdraw Defendant’s guilty plea, concluding that Defendant failed to establish newly discovered evidence resulting in manifest injustice, and concluded that it did not have jurisdiction to consider a sentence reduction because Defendant’s motion was untimely. Defendant appealed. The Supreme Court dismissed the appeal, holding that the district court did not have jurisdiction to rule on Defendant’s motion, and therefore, this Court did not have jurisdiction to consider Defendant’s appeal. View "Shue v. State" on Justia Law

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Mother and Father separated in 2005, when their child was ten months old, and largely shared parenting of the child. In 2012, Father filed a petition to establish custody, visitation, and child support. The district court first issued a temporary custody order addressing temporary custody, visitation, and child support during the pendency of the custody action. After a trial, the district court issued a final custody order awarding primary custody to Father and granting Mother liberal visitation rights. The Supreme Court affirmed, holding (1) the district court did not err in treating its final custody order as an initial custody determination rather than as a modification of an existing custody order; and (2) the district court did not abuse its discretion in its consideration and weighting of the status quo and the child’s custody preference in making its custody determination. View "Demers v. Nicks" on Justia Law

Posted in: Family Law
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This matter arose following the Supreme Court’s opinion in Wallop Canyon Ranch, LLC v. Goodwyn, in which the Supreme Court affirmed a district court order awarding Scott Goodwyn attorney fees pursuant to Wyo. Stat. Ann. 17-14-1104. Goodwyn subsequently filed a motion to recover appellate attorney fees. The district court denied the application, concluding that Goodwyn was required to file his motion with the Wyoming Supreme Court before the mandate issued. The Supreme Court dismissed Goodwyn’s appeal on the merits, holding that the district court’s order denying Goodwyn’s motion for appellate attorney fees was a correct application of the law. View "Goodwyn v. Wallop" on Justia Law

Posted in: Civil Procedure
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After a jury trial, Defendant was convicted of two counts of first degree murder and one count of attempted first degree murder. The jury trial began 210 days after Defendant’s arrest and 869 days after his arraignment. The district court sentenced Defendant to three consecutive sentences of life without the possibility of parole. The Supreme Court affirmed, holding (1) there was no violation of Defendant’s right to a speedy trial under Wyo. R. Crim. P. 48 and the Wyoming and United States Constitutions; (2) Defendant was not denied the effective assistance of counsel by his first appointed counsel; and (3) the district court did not abuse its discretion when it denied Defendant’s challenges for cause against two jurors. View "Castellanos v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of two counts of second degree sexual abuse of a minor. Defendant appealed, arguing that the district court erred by refusing his proffered instruction defining the term “inflicts” as used in the charged statute and that the district court erred by refusing to give a definition after the jury requested a dictionary. The Supreme Court affirmed, holding that the district court did not err in refusing Defendant’s proposed instruction or in failing to provide the jury with Defendant’s proffered definition of the term “inflicts” in response to the jury’s request for a dictionary. View "Marfil v. State" on Justia Law

Posted in: Criminal Law
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Leon and Brenda Rogers purchased a home from Jeffrey Wright. The Rogers subsequently discovered several defects in the home and sued Wright, JWright Development, LLC, and JWright Companies, Inc. (collectively, the JWright defendants), alleging breach of contract, negligence, breach of warranty, and negligent and intentional misrepresentation. The district court granted summary judgment in favor of the JWright defendants. The Supreme Court reversed the district court’s order on the negligence claim but otherwise affirmed, holding (1) issues of material fact existed regarding whether the builder of the Rogers’ home breached its legal duty to build the home in a reasonable and workmanlike manner; and (2) the district court properly granted summary judgment in favor of the JWright defendants on the remainder of the Rogers’ claims. View "Rogers v. Wright" on Justia Law