Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of aggravated assault and battery. Defendant appealed, arguing that the prosecutor committed prosecutorial misconduct by incorrectly instructing the jury regarding the presumption of innocence and by attempting to define “reasonable doubt” to the jury in his closing argument. The Supreme Court affirmed, holding (1) the prosecutor violated a clear and unequivocal rule of law when he made an incorrect statement regarding the presumption of innocence; (2) the prosecutor transgressed a clear and unequivocal rule of law when he defined reasonable doubt for the jury in his closing argument; but (3) while Defendant established that the prosecutor committed two errors that transgressed clear and unequivocal rules of law, the cumulative effect of these errors was not prejudicial. View "Watts v. State" on Justia Law

After just more than three years of marriage, Wife sued Husband for divorce. Wife subsequently filed a motion to amend her complaint to add a cause of action for promissory estoppel. The district court denied the motion, concluding that justice did not require leave to amend the complaint. The district court then distributed the couple’s property and property-related obligations to the party who brought it into the marriage. If an asset was purchased during the marriage, the court awarded it to the party whose assets were used to purchase it. The court awarded Wife an additional $45,000 equalization payment. Wife appealed. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in denying Wife’s motion for leave to amend; and (2) the district court’s distribution of the couple’s property was not an abuse of discretion. View "Dane v. Dane" on Justia Law

When Child was approximately one year old, Mother left Child in the care of Aunt, Mother’s sister. Aunt was appointed temporary guardian of Child. Aunt then filed a petition for permanent guardianship. After an evidentiary hearing, the district court denied the motion, ruling that Aunt failed to establish by a preponderance of the evidence that Mother and Father were unfit as parents. The Supreme Court affirmed, holding (1) the district court applied the correct burden of proof in evaluating whether Aunt had proven that Mother and Father were unfit; and (2) the district court’s finding that Aunt did not establish by a preponderance of the evidence that Mother and Father was no clearly erroneous, inconsistent with the evidence, or contrary to the great weight of the evidence. View "Eshleman v. Rosenberg" on Justia Law

Pennaco Energy Inc. acquired mineral leases beneath a surface estate owned by Brett Sorenson, Trustee of the Brett L. Sorenson Trust. A surface damage and use agreement between the parties granted Pennaco access to and use of the land for exploration and production of minerals, and, in return, required Pennaco to pay for the damage to and use of the surface estate, and to reclaim the land once operations ended. When Pennaco refused to perform its obligations under the contract, Soreson brought this lawsuit. The jury rendered a verdict finding that Sorenson suffered more than $1 million in damages. The district court entered judgment on the jury’s verdict and also awarded Sorenson costs and attorney fees. The Supreme Court affirmed, holding that the district court did not err by (1) ruling that Pennaco remained liable under the surface damage and use agreement after assignment, and (2) using a 2.5 multiplier to enhance the lodestar amount in awarding attorney fees. View "Pennaco Energy, Inc. v. Sorenson" on Justia Law

After Father and Mother separated, the parties’ child lived with Mother. Father later filed a petition to establish paternity and visitation, and, eventually, regular visitation between Father and the child was established. Father subsequently amended his petition to seek custody of the child. After a trial, the district court granted custody of the child to Father, subject to Mother’s visitation rights. Mother appealed, asserting that the district court abused its discretion when it refused to allow the child’s therapist to give opinion testimony at the custody hearing. The Supreme Court affirmed, holding that the district court did not abuse its discretion by excluding the therapist’s opinion testimony because Mother did not comply with her discovery obligations. View "JN v. RFSG" on Justia Law

Defendant was charged with felony interference with a peace officer. Ultimately, the case was submitted to the jury. The jury deliberated for approximately four hours before it informed the district court that it was deadlocked. After discussion with counsel, the district court gave the jury a supplemental instruction asking the jurors to continue their deliberations. Less than one hour later, the jury returned a guilty verdict. Defendant appealed, arguing that the court’s supplemental instruction improperly coerced the jury and that his attorney provided ineffective assistance by failing to object to the instruction. The Supreme Court affirmed, holding (1) the supplemental instruction was not unduly coercive; and (2) defense counsel’s failure to object to the jury instruction did not constitute deficient performance. View "Carter v. State" on Justia Law

Defendant pleaded guilty to manslaughter and aggravated burglary. Defendant was sentenced to twelve to eighteen years for the manslaughter conviction and eight to ten years for the aggravated battery, to run concurrently, with a recommendation for the Youthful Offender Program (boot camp). After Defendant completed boot camp he moved for a sentence reduction to probation. The district court denied the motion but reduced Defendant’s sentence by two years. The Supreme Court affirmed, holding (1) following the successful completion of boot camp the sentencing court has discretion to reduce the sentence of an applicant upon completion of boot camp, and that discretion allows a reduction in sentence that could include probation but could also include other possibilities; (2) the district court did not abuse its discretion when it considered the nature of Defendant’s underlying crimes in Defendant’s motion for sentence reduction; and (3) the prosecutor did not violate the terms of the plea agreement when he argued against probation after completion of boot camp. View "Mendoza v. State" on Justia Law

In 2013, Appellant was convicted of ten felonies for acts perpetrated against his ex-girlfriend, their son, and Appellant’s six-year-old second cousin. The Supreme Court affirmed. In 2015, Appellant filed a motion for a new trial based on a recantation by his ex-girlfriend. The district court denied the motion. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Appellant’s motion for a new trial where the court found that the ex-girlfriend’s post-trial recantation was not credible and the court’s assessment that the ex-girlfriend’s “recantation of her recantation” constituted cumulative evidence relating to her credibility. View "Lindstrom v. State" on Justia Law

Appellant was convicted of kidnapping and felony stalking. The Supreme Court reversed the stalking conviction but affirmed the kidnapping conviction. On remand, the district court amended the sentencing order. Appellant subsequently filed a motion and a second motion to correct an illegal sentence, arguing that the amended sentence improperly increased his punishment for kidnapping, that the public defender who represented him at trial improperly approved the amended sentence, and that the jury had been improperly instructed at trial. The district court denied the motions. The Supreme Court affirmed the denial of Appellant’s motions, holding that Appellant failed to establish that his amended kidnapping sentence was illegal. View "Hawes v. Wyoming" on Justia Law

Several individuals (collectively, “the Wimers”) filed a complaint against their neighbors (collectively, “the Cooks”) seeking an injunction prohibiting the Cooks from carrying out their plan of placing multiple single-family housing structures on a twenty-acre parcel of land, alleging that the Cooks’ plan for the property violated the neighborhood’s covenants. The Cooks counterclaimed and filed a third-party complaint against all of the landowners in the area seeking a declaration that the covenants had been abandoned due to various covenant violations. The district court determined that the covenants had not been abandoned and that the Cooks’ plan to develop the land did not violate the covenants. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) properly concluded that the covenants were not abandoned; and (2) erred in concluding that the Cooks’ plan did not violate the covenants, as the covenants prohibit multiple single-family dwellings on a parcel. View "Wimer v. Cook" on Justia Law