Justia Wyoming Supreme Court Opinion Summaries

First American Title Insurance Company issued title insurance policies to the predecessors of North Fork Land & Cattle, LLLP. When North Fork learned that Bunker Road, which crosses three of North Fork’s properties, was established as a county road, North Fork submitted notices of claims under the title insurance policies, asserting that First American failed to disclose to one of North Fork’s predecessors that Bunker Road burdened the properties and that it was damaged by the Bunker Road encumbrance. First American did not respond to North Fork’s claims, and North Fork filed suit against First American. The district court granted summary judgment in favor of First American, concluding that North Fork did not meet the definition of “insured” under the title insurance policies. The Supreme Court reversed, holding that North Fork is a covered insured under the terms of the title insurance policy. Remanded. View "N. Fork Land & Cattle, LLLP v. First Am. Title Ins. Co." on Justia Law

After a jury trial, Defendant was found guilty of driving a vehicle while under the influence of intoxicating liquor or controlled substances and was sentenced to six to seven years’ confinement. The Supreme Court affirmed, holding (1) Defendant failed to carry his burden of showing that Wyo. Stat. Ann. 31-5-233(b)(iii)(C) is unconstitutionally vague as applied to Defendant’s conduct; and (2) Defendant failed to carry his burden of showing that his trial attorneys were constitutionally ineffective in failing to present evidence relating to the concentration of alcohol and tetrahydrocannabinol in Defendant’s blood. View "Guilford v. State" on Justia Law

Appellant, an inmate at the Wyoming Medium Correctional Institution, filed a petition for declaratory judgment asking the district court to find that Steve Hargett, the warden of the institution, and Robert Lampert, the director of the Department Prison Division, violated the Wyoming Public Records Act (WPRA) by delaying the production of a record he had requested under the WPRA. Appellant also asked the district court to declare that the Department of Corrections had to produce certain types of records if he requested them in the future. After Appellants filed a motion to dismiss, Appellant filed a motion to amend his petition. The district court dismissed the petition, finding that it did not have jurisdiction under the WPRA to provide the relief Appellant was seeking. The district court did not expressly rule on the motion to amend. The Supreme Court affirmed, holding (1) the district court properly dismissed Appellant’s petition because the relief Appellant sought was not available under the WPRA; and (2) the district court did not abuse its discretion by implicitly denying the motion to amend, as the proposed amendment was futile. View "Guy v. Lampert" on Justia Law

A road crosses the corner of a parcel of property owned by Boyd Van Fleet. A dispute arose between Van Fleet and Appellants concerning Appellants’ ownership and right to use that portion of the road in conjunction with bentonite mining operations. Appellants sued Van Fleet, asserting several claims, including prescriptive easement and adverse possession. Van Fleet counterclaimed for, inter alia, trespass/nuisance, damage to property, ejectment, and an injunction prohibiting Appellants from using the portion of the road on his property. The district court entered a judgment ruling generally in favor of Van Fleet. The Supreme Court affirmed, holding that the district court did not err in finding that Appellants failed to prove their claims for adverse possession and prescriptive easement and that Van Fleet owned the land where the road traversed his property free of any right for them to use it. View "Wyo-Ben, Inc., v. Van Fleet" on Justia Law

Keizer Trailer Sales, Inc., which was insured by Continental Western Insurance Company (CWIC), sold three trailers to James Black. The installment purchase agreement stated that Keizer would remain the owner of the trailers under the purchase price was paid in full. Black was subsequently involved in an accident while pulling a Keizer trailer that resulted in one fatality and multiple injuries. Wrongful death and negligence claims were filed against Black and his business. CWIC filed a complaint for declaratory judgment seeking a declaration that the commercial and umbrella policies it issued to Keizer on the trailer involved in the accident did not provide coverage for the claims arising from Black’s accident. The district court ruled against CWIC, concluding that Black was insured under the policies’ omnibus clauses because he was driving a vehicle owned by Keizer with Keizer’s permission. The Supreme Court affirmed, holding that because Keizer retained ownership of the trailers, and because Black’s use of the trailers was with Keizer’s permission, coverage was available under the omnibus clauses of Keizer’s CWIC policies. View "Continental W. Ins. Co. v. James Black, JJ Bugs, Ltd." on Justia Law

In 1994, Appellant was charged with four counts of first-degree sexual assault and one count of aggravated assault and battery. Appellant entered a plea pursuant to a plea agreement under which the State dismissed all but one of the counts, which it reduced. Appellant pled no contest to the remaining reduced count. In 2013, Appellant was charged with five counts of first-degree rape and three counts of first-degree sexual assault. After a jury trial, Appellant was convicted of four counts of first-degree rape and three counts of first-degree sexual assault. The Supreme Court affirmed, holding (1) the trial court did not violate Appellant’s constitutional right to a speedy trial, as the recent charges concerned crimes committed against victims other than the victim at issue in the 1994 charges; and (2) the prosecution did not violate the 1994 plea agreement by bringing charges against Appellant for those crimes in the present case. View "Nordwall v. State" on Justia Law

Plaintiff executed a non-compete agreement restricting her ability to compete with an accounting firm that she sold to Defendant. Before the non-compete agreement expired, Plaintiff was awarded the position of office manager with a former client. Claiming that Plaintiff’s new employment was a violation of the non-compete agreement, Defendant stopped payments on a promissory note that was parties of the parties’ purchase agreement. Plaintiff responded by filing suit, alleging that Defendant breached the promissory note. Defendant counterclaimed, asserting that Plaintiff had breached the contract and the implied covenant of good faith and fair dealing. The district court concluded that Plaintiff had not violated the non-compete agreement and further found that Defendant had breached the terms of the promissory note. The Supreme Court affirmed, holding that the district court correctly found that Plaintiff’s employment fell within an exception to the non-compete agreement and therefore did not err when it found Plaintiff did not violate the non-compete agreement. View "Pope v. Rosenberg" on Justia Law

During the 2011-2012 school year, Plaintiff was a continuing contract teacher who worked for the Laramie County School District No. One. In spring of 2012, the District Superintendent gave Plaintiff notice that he proposed that Kinstler be terminated. On September 4, 2012, a hearing officer recommended that the District accept the Superintendent’s proposal. On September 17, 2012, the District’s Board of Trustees voted to accept the recommendation. Kinstler was paid his normal salary from August 15, 2012, the date he would have started to work, through the date that the Board acted on the recommendation to terminate him. Kinstler subsequently sued the District, asserting that the District failed to pay him the salary and value of benefits allegedly owed him for the 2012-2013 academic year. The district court partially granted Kinstler’s motion for summary judgment and entered an order with respect to his salary and benefits claim. The Supreme Court reversed and vacated the award, holding that because Kinstler’s termination was effective at the end of the 2011-2012 school year, he had no statutory right to compensation following that date. View "Laramie County Sch. Dist. v. Kinstler" on Justia Law

In 2014, Appellant filed a Wyo. R. Civ. P. 60(b)(4) motion seeking to set aside a 1999 default judgment granting Appellee a divorce. In support of her motion, Appellant alleged that the default judgment was void because the district court lacked jurisdiction to enter the default judgment against her. The circuit court denied the motion, finding that the motion was not filed within a reasonable time. The Supreme Court affirmed, holding (1) the district court erred in rejecting Appellant’s Rule 60(b)(4) motion based solely on Appellant’s delay in filing the motion, as Rule 60(b)’s time limitations do not generally apply to Rule 60(b)(4) motions to set aside a judgment as void; but (2) none of the defects Appellant alleged in the district court’s default judgment rendered the judgment void for lack of jurisdiction. View "Linch v. Linch" on Justia Law

After a jury trial, Defendant was found guilty of domestic battery and possession of a weapon with intent to threaten. Defendant appealed, arguing (1) the prosecutor improperly asked him a series of questions during his testimony at trial in which the prosecutor repeated statements made by Defendant’s daughter and asked, “was she lying?”; and (2) the district court abused its discretion when it allowed evidence of prior discharge of a gun. The Supreme Court reversed, holding (1) the prosecutor’s questioning was improper, and the error was prejudicial; and (2) the absence of appropriate findings and discussion regarding the admission of the discharge evidence hinders review of the district court’s decision to admit the evidence. Remanded. View "McGinn v. State" on Justia Law