Justia Wyoming Supreme Court Opinion Summaries

Husband and Wife divorced in 2014. Wife appealed from the judgment of divorce, arguing that the district court abused its discretion in not awarding her alimony, erred in its property division, and erred in finding that Wife was able to work. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in not awarding alimony despite Wife’s five-year time limit in her request; (2) the district court equitably divided the marital property; and (3) the district court did not err in finding that Wife could conceivably work. View "Kamm v. Kamm" on Justia Law

Appellant pled guilty to escape and received a sentence that was suspended in favor of probation. Appellant’s probation was later revoked and the prison sentence for his escape conviction was re-imposed. Appellant subsequently pled guilty of failing to register and sentenced to a term of confinement. Appellant appealed, arguing that the district court erred by failing to consider his request for credit for time spent in presentence confinement. The Supreme Court affirmed, holding that the district court erred in concluding that it lacked the requisite authority to award credit for time served in presentence confinement. Remanded. View "Askin v. State" on Justia Law

P. Richard Meyer executed a last will and testament in 2008, bequeathing all of his property to his fourth wife, Miracles Meyer, and naming her as his personal representative. The will complied with the form for self-proving wills set forth in Wyo. Stat. Ann. 2-6-114. Mr. Meyer died in 2013. When Mrs. Meyer filed a petition to probate the will, Kelly Fanning, Mr. Meyer’s child from a previous marriage, filed a petition to revoke the order admitting the will to probate on the grounds that the witnesses could not recall having seen Mr. Meyer or each other sign the will. The district court granted summary judgment in favor of Fanning, concluding that the will was not a self-proving will and that the will could not be proven. The Supreme Court reversed, holding that the district court erred when it concluded that, in all cases where a will is not self-proving, the proponent must establish that the witnesses signed the will in the presence of each other and in the presence of the testator. Remanded. View "Meyer v. Fanning" on Justia Law

Defendant was convicted of two counts of first-degree sexual assault and one count of kidnapping. The Supreme Court affirmed, holding (1) the district court did not commit plain error by failing to instruct the jury on the “incidental rule,” i.e., that confinement would not support a kidnapping conviction unless it was separate from and not merely an incident of the sexual assaults; and (2) there was no plain error in the district court’s reply to a question from the jury that the jurors should review the instructions already given by the court. View "Vaught v. State" on Justia Law

Appellant filed a 42 U.S.C. 1983 civil rights action in the district court asserting four federal constitutional claims and one state law claim, alleging that, while he was an inmate in the state of Wyoming under the supervision and control of the Wyoming Department of Corrections (DOC), he was deprived of his personal property, which violated his right to due process and caused him injury. The district court granted summary judgment on all claims for the DOC. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of the DOC. View "Chapman v. Wyo. Dep’t of Corr." on Justia Law

Appellant, a long-term Game & Fish employee, was terminated after two disciplinary suspensions and her filing of a complaint alleging hostile work environment sexual harassment, grieving the disciplinary suspensions, and filing a charge of discrimination. The Office of Administrative Hearings concluded that “good cause” supported the disciplinary actions and that they were supported by substantial evidence. The district court affirmed. The Supreme Court affirmed, holding (1) no facts asserted by Appellant adequately supported a due process claim “of such a fundamental nature that it must be considered” for the first time on appeal; and (2) Appellant failed to preserve her claim that her suspensions were issued without authority. View "Crofts v. State ex rel. Dep’t of Game & Fish" on Justia Law

Merit Energy Company, LLC hired an independent contractor, Basic Energy Services, Inc. to clean out its oil and gas wells. Basic employee Blake Horr was injured while performing the job. Horr brought suit against Merit, alleging several exceptions to the general rule that the employer of an independent contractor is not liable for physical harm caused to another by an act or omission of the contractor or his workers. After a jury trial, the district court entered judgment against Merit, concluding that Merit was substantially at fault and that its fault had caused Horr more than two million dollars in damages. The Supreme Court affirmed, holding that the district court (1) did not err in instructing the jury to determine if Merit retained control over any part of the work that caused injury to Horr; (2) did not abuse its discretion by refusing to give the jury Merit’s proposed instruction detailing Basic’s duty of care to Horr; and (3) did not err in denying Merit’s motion for judgment as a matter of law. View "Merit Energy Co., LLC v. Horr" on Justia Law

After a jury trial, Appellant was convicted of second-degree murder. The Supreme Court affirmed the conviction, holding that the district court did not err or abuse its discretion in (1) excluding evidence relating to the victim’s criminal history; (2) excluding Appellant’s proposed expert testimony regarding the character traits of persons who view depictions of child pornography; (3) declining Appellant’s request to instruct the jury regarding self-defense in a home or habitation; (4) instructing the jury, in relation to Appellant’s claim of self-defense, that it must determine whether Appellant or the victim was the first aggressor in this case; and (5) permitting the State to introduce Wyo. R. Evid. 404(b) evidence despite the State’s late notice of its intent to use the evidence. View "Knospler v. State" on Justia Law

In 2012, Robert Bratton filed a petition to be appointed the guardian of William Bratton, Robert’s brother. Jeanne Blenkinsop, William’s sister, responded with a counter petition seeking to be appointed guardian and conservator. The district court subsequently granted permanent guardianship and conservatorship to Blenkinsop and dismissed Robert’s petition. Thereafter, Blenkinsop filed a Guardian’s Second Report with the district court. The district court ratified and approved the report, thus rejecting Robert’s objections to the report. Blenkinsop later filed a “Conservator’s First Annual Accounting.” The district court confirmed and approved the accounting. Robert appealed. The Supreme Court affirmed the district court’s decisions accepting the Guardian’s Second Report and the Conservator’s First Annual Accounting, holding (1) the district court did not err in its judgments; and (2) because there was no reasonable cause for these appeals, Blenkinsop was entitled to reasonable attorney’s fees and costs. View "Bratton v. Blenkinsop" on Justia Law

After a jury trial, Appellant was convicted of aggravated assault and battery, simple assault, and strangulation of a household member. The Supreme Court affirmed Appellant’s conviction and sentence for aggravated assault and battery but reversed Appellant’s assault conviction and remanded for an order vacating that conviction and sentence, holding that the district court (1) did not commit plain error in instructing the jury on the elements of aggravated assault and battery under Wyo. Stat. Ann. 6-2-502(a)(i); but (2) erred in instructing the jury to consider assault as a lesser included offense of aggravated assault and battery under Wyo. Stat. Ann. 6-2-502(a)(iii), and the instruction was necessarily prejudicial to Appellant. View "Cecil v. State" on Justia Law