Justia Wyoming Supreme Court Opinion Summaries

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

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

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

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

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

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