Justia Wyoming Supreme Court Opinion Summaries

Plaintiff, a non-Indian, filed a complaint in state district court against Defendants, enrolled members of the Northern Arapaho Tribe, for injuries sustained in a vehicle accident that occurred on a state highway within the boundaries of the Wind River Indian Reservation. Defendants moved for summary judgment, asserting (1) the district court lacked subject matter jurisdiction, and (2) the two-year statute of limitations dictated by the Shoshone and Arapaho Law and Order Code should apply to bar Plaintiff’s action. The district court denied the motion, concluding (1) the court’s exercise of jurisdiction would not infringe on tribal sovereignty, and (2) the court had at a minimum concurrent jurisdiction over the action. The Supreme Court affirmed, holding that the district court (1) had subject matter jurisdiction over this action, and (2) properly concluded that Plaintiff’s action was timely filed under Wyoming’s four-year statute of limitations. View "C'hair v. Dist. Court" on Justia Law

Taylor Lysager, who was five years old, was attending a community basketball game at a former school building in Etna, Wyoming when lunchroom bench propped against the wall fell on him, causing a fatal skull fracture. Lysager’s personal representative filed a wrongful death action against Lincoln County School District No. 2 (School District), the Town of Thayne, and the Lincoln County Board of County Commissioners (Lincoln County). Lincoln County filed an affidavit of noninvolvement in lieu of an answer, and the district court dismissed Lincoln County from the action without prejudice based on the affidavit of noninvolvement. The School District filed a motion for summary judgment arguing that it did not breach its duty of care and that its actions were not the proximate cause of Lysager’s injuries. The court entered summary judgment for the School District. Plaintiff appealed both orders. The Supreme Court (1) dismissed the appeal of the district court’s order dismissing the complaint against Lincoln County, holding that the order was not a final appealable order; and (2) reversed the entry of summary judgment for the School District, holding that while the material facts are largely undisputed, reasonable minds could differ in answering the questions of proximate and intervening cause. View "Amos v. Lincoln County Sch. Dist. No. 2" on Justia Law

Wife filed for divorce from Husband. The parties reached a settlement agreement as to child custody and visitation but were unable to agree concerning child support and the division of property. After a trial, the district court entered a decree dividing the marital property. Husband appealed, arguing that the district court abused its discretion in valuing his interest in the family business and requiring him to make a lump sum payment to Wife. The Supreme Court affirmed, holding that the district court did not abuse its discretion in ordering Husband to pay the amount owed to Wife in a lump sum and in accepting the capitalization of earnings method for valuing the business. View "Stephen v. Stephen" on Justia Law

Phillip Sam was charged as an adult with one count of first degree murder and twelve counts of aggravated assault. Sam was sixteen years old at the time of the offense, and several witnesses set to testify at trial were juveniles. After a hearing, the district court entered an order concerning media access during trial that limited the identification of juvenile witnesses who would testify during the trial in open court, concluding that this measure was necessary because some of the juvenile witnesses had been the subject of threats. Petitioner, a newspaper, challenged the prior restraint on publication imposed by the court. The Supreme Court reversed and vacated the district court’s order pertaining to the release of the names of juvenile witnesses, holding that the district court’s order violated the First Amendment because this was not the sort of exceptional case where the district court’s prior restraint on speech survives constitutional scrutiny. View "Cheyenne Newspapers, Inc. v. First Judicial Dist. Court" on Justia Law

Sheri Eaton requested workers’ compensation benefits claiming that she received a workplace injury resulting from an injury at her workplace. After a contested case hearing, the Office of Administrative Hearings (OAH) determined that Eaton did not prove that her injury was related to the workplace event. The OAH also upheld the final determination by the Division ceasing payments for temporary total disability benefits and mental health treatment six months after reaching maximum medical improvement. The district court affirmed the OAH’s decision. The Supreme Court affirmed the district court’s order, holding that the OAH hearing examiner’s decision was supported by substantial evidence and that the OAH’s determination was not arbitrary or capricious. View "Eaton v. State ex rel. Dep’t of Workforce Servs." on Justia Law

In 1994, Appellant pled guilty to kidnapping and and first-degree sexual assault while he was on parole for an unrelated crime. Appellant was sentenced to two concurrent terms of life imprisonment. In 2014, Appellant, acting pro se, filed a second motion to correct illegal sentence. The district court awarded Appellant thirty-seven days of credit for presentence confinement and denied the remainder of Appellant’s claims. The Supreme Court affirmed, holding that the district court did not err in denying Appellant’s motion to correct an illegal sentence under the circumstances of this case. View "Bird v. State" on Justia Law

Electrical Wholesale Supply Co. (EWS) filed this action seeking payment for electrical materials it supplied to a commercial building remodel. EWS sued, among other defendants, Alane Fraser, the owner of the commercial property, and M.J. Bishop Concrete & Construction, Inc. (Bishop Construction), the general contractor, for foreclosure of a construction lien, breach of contract, unjust enrichment, and third party beneficiary. The circuit court denied EWS’s claims. The district court affirmed. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the circuit court (1) applied the wrong statute to the lien notice issue and erred by granting summary judgment in favor of Fraser on the lien claim; but (2) did not err in concluding that EWS did not prove its unjust enrichment claim against Fraser and Bishop Construction. View "Elec. Wholesale Supply Co., Inc. v. Fraser" on Justia Law

Appellant received a back injury while working as a concrete truck driver. Appellant subsequently received two surgeries to his back and could not return to work. The Wyoming Workers’ Safety and Compensation Division assigned Appellant a nine percent permanent partial impairment (PPI) rating. The Medical Commission sustained the Division’s PPI rating. The Supreme Court affirmed, holding that the Medical Commission’s decision that Appellant did not prove he was entitled to a higher impairment rating under the AMA Guides to the Evaluation of Physical Impairment was supported by substantial evidence and otherwise in accordance with the law. View "In re Worker's Compensation Claim of Michael D. Hurt" on Justia Law

In the third and final phase of the general adjudication of water rights in the Big Horn River, the Wyoming Board of Control recommended elimination of certain unused and unadjudicated water rights under Farmers Canal Permit 854, including that rights to irrigate Tract 109. Frank Mohr, the owner of Tract 109, objected, admitting that Tract 109 had never been adjudicated under the Farmers Canal Permit but was adjudicated under the Perkins Ditch Enlargment Permit. In conjunction with his application for that permit, Mohr’s predecessor submitted an affidavit relinquishing his right to water under the Farmers Canal Permit. The Special Master recommended elimination of Tract 109 from the Farmers Canal Permit, finding that relinquishment of the Farmers Canal Permit by Mohr’s predecessor was final and not subject to attack by Mohr. The district court approved the Special Master’s recommendation, concluding that Tract 109 was serviced under the Perkins Ditch Enlargement and not the Farmers Canal Permit. The Supreme Court affirmed, holding (1) Mohr was bound by the acts of his predecessor-in-interest and the previous adjudication of water rights to Tract 109; and (2) the district court gave Mohr a fair opportunity to present his case in accordance with the Wyoming Rules of Civil Procedure. View "In re Gen. Adjudication of All Rights to Use Water in Big Horn River Sys." on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree sexual abuse of a minor for sexually assaulting his teenage daughter. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting certain uncharged misconduct at trial; (2) Defendant’s trial counsel did not provide ineffective assistance by not uncovering certain evidence in time to be used at trial; and (3) Defendant’s due process rights were not violated when his appeal was delayed due to the court reporter’s untimely filing of the transcripts from the proceedings below. View "Hodge v. State" on Justia Law