Justia Wyoming Supreme Court Opinion Summaries

Appellant suffered a workplace injury to his back and applied for permanent partial disability. The Workers’ Compensation Division denied benefits. Appellant requested a contested case hearing. During discovery, the Division served interrogatories and requests for production requesting information regarding Appellant’s work history since the time of his injury. Appellant objected to a number of the interrogatories and requests, asserting his Fifth Amendment right against self-incrimination. The hearing examiner compelled Appellant to answer the discovery, but Appellant continued to invoke his Fifth Amendment right against self-incrimination. The hearing examiner dismissed the contested case as a discovery sanction. The district court affirmed. The Supreme Court reversed, holding (1) Appellant was justified in asserting his Fifth Amendment privilege against self-incrimination because he reasonably believed his answers to the discovery requests could be used in a criminal prosecution against him; and (2) the hearing examiner abused his discretion by acting arbitrarily and capriciously in dismissing the case as a discovery sanction without engaging in the proper balancing of Appellant’s and the Division’s conflicting interests. View "Debyah v. State, ex rel., Dep’t of Workforce Servs." on Justia Law

After a jury trial, Defendant was convicted for aiding and abetting aggravated robbery. Defendant appealed, asserting that the district court denied him the right to due process when it refused to instruct the jury on his defense of duress. The Supreme Court reversed and remanded for a new trial, holding that the district court denied Defendant of his right to a fair trial when it ruled that the duress defense instruction would not be given to the jury after Defendant testified and admitted the elements of the crime, as the facts of the case were sufficient to establish a jury question as to Defendant’s duress defense. View "James v. State" on Justia Law

After a jury trial, Defendant was found guilty of one count of second degree sexual abuse of a minor. Defendant appealed, arguing that prosecutorial misconduct occurred in four instances. The Supreme Court affirmed, holding (1) the prosecutor’s comments on defense counsel’s failure to produce certain evidence did not prejudice Defendant; (2) prosecutorial misconduct did not occur when the prosecutor commented on the fact that Defendant did not confess to the crime charged; and (3) the prosecutor did not elicit opinions concerning witness credibility or personally vouch for the credibility of a witness. View "Collins v. State" on Justia Law

After a trial, Defendant was convicted of five counts of sexual abuse of a minor in the first degree. Defendant appealed, arguing that the district court committed plain error by admitting testimony about the presumption of paternity applicable to DNA evidence that showed Defendant impregnated his minor victim. The Supreme Court affirmed, holding (1) there was no plain error where the testimony in question was only relevant to support Wyo. R. Evid. 404(b) evidence rather than any elements of the charged office; and (2) Defendant’s due process rights were not violated where there was no indication that the State relied on this evidence to shift its burden of proof to Defendant. View "Snyder v. State" on Justia Law

After Elda Coborn died intestate, Appellants, Coborn’s daughters, filed an application for a summary decree of distribution in Laramie County, Wyoming. The district court granted the application in part, distributing the personal property and real property located in Laramie County, but denied the application with regard to the mineral interests in Campbell and Johnson Counties based on its determination that it lacked the authority to order summary distribution of the decedent’s real property interests located in counties other than Laramie County. The Supreme Court reversed, holding that Wyo. Stat. Ann. 2-1-205 did not require Appellants to file a petition for summary distribution in every county in which the decedent’s property was located. View "In re Estate of Coborn" on Justia Law

In 2011, Appellant suffered a work-related injury. The Department of Workforce Services, Workers’ Compensation Division approved benefits for the jury to Appellant’s left groin, abdomen, upper leg, and knee. After Appellant returned to work, he began experiencing back pain. Appellant filed a claim for the evaluation and treatment of his back pain. The Division denied the claim, concluding that the lumbar spine evaluation and treatment Appellant had received were not related to his originally work injury. The Office of Administrative Hearings (OAH) denied Appellant’s worker’s compensation claim on the grounds that he failed to prove a causal relationship between his lower back problems and his work-related accident. The district court upheld the OAH’s decision. The Supreme Court affirmed, holding (1) the hearing examiner’s conclusion that Appellant’s back problem was not caused by the work-related accident was supported by substantial evidence; and (2) the hearing examiner correctly ruled that Appellant was not entitled to worker’s compensation benefits under the second compensable injury rule. View "In re Worker's Comp. Claim of Guerrero" on Justia Law

After a jury trial, Defendant was found guilty of felony theft. The Supreme Court affirmed, holding (1) there was sufficient evidence for the jury to reasonably conclude that Defendant possessed the requisite intent to deprive; (2) the district court did not abuse its discretion when it imposed no sanction for the State’s discovery violation; (3) the district court erred when when it allowed evidence of Defendant’s prior felony conviction, but the error was harmless; (4) the district court did not commit plain error when it prohibited defense counsel from questioning a police officer about Defendant’s “nonstatements” made during his interview following his arrest; and (5) Defendant waived his right to challenge the district court’s response to the jury question under the invited error doctrine. View "Toth v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree sexual abuse of a minor and one count of second-degree sexual abuse of a minor. The Supreme Court affirmed, holding (1) the district court did not err in admitting evidence of Appellant’s prior conviction for sexual assault; (2) the district court did not err in excluding evidence of the victim’s prior sexual conduct; (3) the district court did not err in admitting evidence of domestic abuse; and (4) the prosecutor did not commit misconduct in his statements made during closing argument. View "Carroll v. State" on Justia Law

After a jury trial, Defendant was convicted of strangulation of a household member. Defendant appealed, arguing that the district court committed reversible error by failing to instruct the jury on the lesser included offenses of battery and domestic battery. Because of the dates the statutes in question went into effect, the question for the Supreme Court’s determination was whether the district court should have instructed the jury on the offense of battery. The Supreme Court affirmed, holding that the district court did not err in refusing Appellant’s lesser included offense instruction because there was no evidence to support it. View "Nickels v. State" on Justia Law

Appellee sued Appellant for trespassing on his property. Because Appellant’s counsel did not appear at the final pretrial conference and otherwise failed to comply with the scheduling order previously set forth, the district court sanctioned Appellant by limiting his presentation of evidence at trial to testifying himself and cross-examining witnesses called by Appellee. Ultimately, the court ruled in favor of Appellee. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court (1) did not abuse its discretion in sanctioning Appellant as it did for his attorney’s failure to comply with discovery procedures; (2) did not err in ruling that Appellant trespassed upon Appellee’s property; (3) did not commit clear error when it awarded damages for reclamation resulting from Appellant’s trespasses; but (4) erred in awarding an amount for damages resulting from Appellant’s camper and pickup truck being parked on Appellee’s property from November 4, 2011 until the date of trial. Remanded. View "Goforth v. Fifield" on Justia Law