Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of five counts of reckless endangering, three counts of aggravated assault, and one count of eluding police. The Supreme Court affirmed, holding (1) there was sufficient evidence presented at trial to convict Defendant of aggravated assault; (2) the district court erred in admitting evidence of law enforcement officers’ subjective reactions to a fired shot, but the error was not prejudicial; (3) the district court did not abuse its discretion when it denied Defendant’s motion for mistrial based upon prosecutorial misconduct; and (4) the prosecutor’s comments during closing argument did not constitute plain error. View "Hill v. State" on Justia Law

Appellant pled guilty to felony shoplifting and was placed on supervised probation for four years. Three years later, the State filed a petition to revoke Appellant’s probation, alleging that she violated the conditions of her probation on two separate occasions. Appellant admitted to the allegations of the petition and was subsequently sentenced to not less than four nor more than six years’ incarceration. Thereafter, Appellant filed a motion for sentence reduction, arguing that her good behavior and rehabilitative progress while incarcerated warranted a reduction. The district court denied the motion. The Supreme Court affirmed, holding (1) Appellant’s productive behavior alone did not require the district court to grant her a sentence reduction; and (2) the district court did not abuse its discretion in denying Appellant’s motion without describing information Appellant provided in support of her request for a reduction. View "Hart v. State" on Justia Law

After a jury trial, Defendant was convicted of misdemeanor unlawful possession of a controlled substance. Because it was Defendant’s third or subsequent offense, he was sentenced to three and a half years in prison with 228 days of credit for time served. Defendant appealed, arguing that there was insufficient evidence to convict him because the State failed to meet its burden to show the form of the substance he was charged with possessing. The Supreme Court affirmed Defendant’s conviction and sentence, holding (1) the pertinent statute does not require that the State prove, as an essential element, the form that was possessed by a defendant; and (2) the State met its burden when it proved that Defendant “knowingly or intentionally possessed a controlled substance[.]” View "Daley v. State" on Justia Law

Due to the county attorney's allegations that Mother neglected Child, the juvenile court temporarily placed Child with Grandmother. Father agreed that Child should remain in the custody of the Department of Family Services (DFS) for placement with Grandmother under a consent decree, which provided that if Mother complied with certain requirements, the neglect action would be dismissed. While the consent decree was pending, Father asserted that he should have custody of Child. The juvenile court entered a permanency order continuing Child in DFS custody. Father appealed. The county attorney subsequently moved to dismiss the case and terminate DFS custody of Child on the grounds that Mother had completed her case plan and complied with the consent decree. The juvenile court dismissed the case. Father also appealed this order. The Supreme Court affirmed, holding (1) the juvenile court did not err when it dismissed the case without a hearing and without making findings; and (2) the other issues raised by Father are moot, and no exception to the mootness doctrine applies. View "DB v. State" on Justia Law

Automation & Electronics, Inc. (A&E) and Consolidated Electric Distributors, Inc. (CE) sued for Red Desert Reclamation, LLC for amounts due on their respective contracts. Pursuant to a stipulation between A&E and Red Desert, the district court entered judgment in favor of A&E. CE was later voluntarily dismissed from the case. A&E subsequently filed a motion for leave to amend its complaint to add CSC Group Holdings, LLC and Cate Street Capital, Inc. as defendants and to add alter ego and fraudulent conveyance claims. The district court granted the motion to amend. The district court then entered two default judgments in favor of A&E making CSC, Cate Street and Red Desert jointly and severally liable on Red Desert’s debt to A&E and setting aside as fraudulent a mortgage granted by Red Desert to CSC, thereby allowing A&E to execute on real property to recover on its judgment against Red Desert. The Supreme Court affirmed, holding that the district court did not lose subject matter jurisdiction over A&E’s motion to amend its complaint after signing off on the stipulated judgment in its favor because A&E was allowed to amend its complaint before CE was voluntarily dismissed from the action. View "CSC Group Holdings, LLC v. Automation & Electronics, Inc." on Justia Law

Father and Mother had one child together when Mother filed for divorce. The district court ordered the parties to share physical custody of the child, alternating between Father’s residence and Mother’s residence until the child reached school age, at which time primary physical custody was awarded to Mother. With regard to the division of the marital estate, the court awarded Father most of the parties’ property and required Father to compensate Mother in the form of an equalizing payment. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) abused its discretion when it ordered shared custody, as the court failed to consider the effect that the shared custody arrangement would have on the child; and (2) did not abuse its discretion in its division of the marital assets and liabilities. Remanded with instructions to award primary physical custody of the child to Mother, with reasonable visitation to Father. View "Williams v. Williams" on Justia Law

Appellant was convicted of felony first-degree murder and sentenced to life without the possibility of parole. Appellant was nineteen years old at the time the murder was committed. Appellant filed a motion seeking a reduction of his sentence of life without the possibility of parole to life as a matter of law. The district court denied Appellant’s motion for sentence reduction. Appellant appealed, arguing that his life sentence without the possibility of parole violates the Eighth Amendment prohibition against cruel and unusual punishment and the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court affirmed on the grounds that Appellant did not raise the constitutional issues below, the equal protection argument was not cogently presented on appeal, and the Eighth Amendment claim was not of a fundamental nature. View "Poitra v. State" on Justia Law

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

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

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