Justia Wyoming Supreme Court Opinion Summaries

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

This dispute arose from promises Defendant Daniel Ochsner allegedly made during Plaintiffs’ several-year tenure living and working on Defendants’ ranch. The district court denied all of Plaintiffs’ claims and Defendants’ counterclaims. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in denying Plaintiffs’ claims to a number of cattle; (2) erred in denying Plaintiffs’ claims to a cattle brand; (3) did not err in denying Plaintiffs’ Wyo. R. Civ. P. 15(b) motion to amend their complaint to conform to the evidence and to add promissory estoppel claims; and (4) did not err in denying Plaintiff’s motion to confirm an alleged settlement agreement between the parties. View "Gould v. Ochsner" on Justia Law

This dispute arose from promises Defendant Daniel Ochsner allegedly made during Plaintiffs’ several-year tenure living and working on Defendants’ ranch. The district court denied all of Plaintiffs’ claims and Defendants’ counterclaims. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in denying Plaintiffs’ claims to a number of cattle; (2) erred in denying Plaintiffs’ claims to a cattle brand; (3) did not err in denying Plaintiffs’ Wyo. R. Civ. P. 15(b) motion to amend their complaint to conform to the evidence and to add promissory estoppel claims; and (4) did not err in denying Plaintiff’s motion to confirm an alleged settlement agreement between the parties. View "Gould v. Ochsner" on Justia Law

Defendant pled guilty to third-degree sexual assault and nolo contedere to abuse of a vulnerable adult. Defendant appealed, arguing that neither plea was informed because the court failed adequately to explain the charges and establish sufficient factual bases. The Supreme Court affirmed, holding that the district court (1) adequately explained the nature of Defendant’s third-degree sexual assault charge and obtained a sufficient factual basis for his guilty plea; and (2) adequately explained the nature of Defendant’s abuse of a vulnerable adult charge, and furthermore, because the court accurately and completely recited the elements of the charge, no other factual basis was necessary prior to accepting the plea. View "Williams v. State" on Justia Law

The State incurred approximately $5,213,000 in suppression costs for the Oil Creek Fire, which it paid or will pay from the State’s Emergency Fire Suppression Account. The State filed a complaint against Black Hills Power (BHP) alleging that BHP was negligent in its inspection, operation and maintenance of a transmission line, which ignited the Oil Creek Fire. The State sought recovery for damages to State-owned property as well as for suppression costs associated with the Oil Creek Fire. BHP moved to dismiss the State’s claim for recovery of fire suppression costs, arguing that the State cannot make a viable claim for recovery of fire suppression costs in the absence of a specific state statute authorizing recovery. The federal court certified to the Supreme Court questions concerning the State’s ability to recover the expenses incurred in suppressing the wildfire. The Supreme Court answered (1) the state cannot generally recover its fire suppression and/or emergency service costs from a party whose negligence created the need for the emergency services because of the free public services doctrine; but (2) the State may recover the costs of its service where portions of the lands protected by the fire suppression effort were State lands. View "State v. Black Hills Power, Inc." on Justia Law

After a jury trial, Appellant was convicted of voluntary manslaughter, a lesser included offense of first-degree murder. At trial, Appellant claimed he was acting in self-defense when he shot the victim. Appellant appealed, arguing that the district court erred in excluding evidence indicating that the victim was under the influence of methamphetamine at the time of the events leading to his death. Specifically, Appellant contended that the evidence was admissible because it was relevant to Appellant’s claim of self-defense. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it excluded any reference to methamphetamine use by the shooting victim, as the evidence was not relevant to Appellant’s self-defense claim. View "Lawrence v. State" on Justia Law

Plaintiff, a high school student, filed suit against his school district and his teacher for injuries he received during a science demonstration conducted in the school gymnasium. Defendants moved for summary judgment under the Wyoming Governmental Claims Act. The district court granted the motion, concluding that Plaintiff’s injury did not fall within any exceptions to governmental immunity. The Supreme Court affirmed, holding that the district court did not err in concluding that Defendants’ alleged negligence did not fall within the exceptions to governmental immunity for negligent operation or maintenance of a building or for negligent operation or maintenance of any recreation area. View "Fugle v. Sublette County Sch. Dist. #9" on Justia Law

When Theresia Breen and Jamie Black divorced, Black was required to provide medical insurance for the parties’ four girls. The decree required the parties to split any medical costs remaining after deductibles were paid by Black and the insurer satisfied its obligations under the policy equally. In 2012, Breen filed a motion seeking Black’s share of medical expenses she had paid incurred for the children. Black paid the requested amount. In 2014, Black filed a motion seeking have Breen held in contempt for failing to pay her required half of the children’s medical expenses that were not paid under his health insurance policy. The district court held Breen in contempt and entered judgment against Breen for the $6,075 it determined she owed Black. The Supreme Court (1) affirmed the civil contempt order except for that portion issuing a judgment to Black for $6,075; and (2) reversed the award of $6,075 because it included amounts Black was barred from seeking due to his failure to prove them after raising them in the 2012 proceedings. Remanded with instructions for the district court to recalculate the amount owed by Breen and to amend its order. View "Breen v. Black" on Justia Law

BHB was born in 2010 to Mother and Father, who were not married. Father filed a petition seeking to establish paternity, custody, visitation, and child support for BHB. After a trial held in 2014, the district court awarded primary custody of four-year-old BHB to Father. The Supreme Court affirmed, holding that the district court did not abuse its discretion in awarding primary custody of BHB to Father after considering all of the evidence and concluding that it was in the best interests of BHB that Father be the primary custodial parent. View "JCLK v. ZHB" on Justia Law

The Smoke Free Committee sought to subject a 2013 Casper City ordinance governing smoking in public places to a referendum vote. The City Clerk determined that the referendum was sixty-one valid signatures short. Plaintiff filed a complaint seeking declaratory and injunctive relief and challenging the City Clerk’s determination. The district court entered an oral ruling in favor of Plaintiff. The Supreme Court affirmed in part and reversed in part, holding (1) the district court had jurisdiction to consider Plaintiff’s declaratory judgment action; (2) the district court did not err in interpreting Wyo. Stat. Ann. 22-23-1005 and related statutes concerning who is a qualified elector registered in a city for purposes of a municipal ordinance referendum petition; and (3) the district court went beyond the realm of declaratory judgment by finding that the City Clerk acted arbitrarily and capriciously in conducting the petition review as he did. View "City of Casper v. Holloway" on Justia Law