Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of aiding and abetting aggravated robbery. Defendant appealed, arguing that the district court denied him the right to due process by declining to instruct the jury on his defense of duress. The Supreme Court reversed and remanded for a new trial, holding that Defendant was denied his right to a fair trial when the district court refused to instruct the jury on Defendant’s defense of duress after Defendant testified and admitted the elements of the crime. Given the evidence presented in this case, Defendant was entitled to a jury determination as to whether he had a reasonable opportunity to avoid the crime. View "James v. State" on Justia Law

Appellee filed the instant action for declaratory relief, claiming to have title to eighty percent of the mineral interest in certain Converse County, Wyoming property pursuant to a 1976 judgment and asserting that Appellants were barred under the doctrine of res judicata from claiming any interest in the property. Appellants argued that only the surface was at issue in the 1976 quiet title action. The district court concluded that res judicata barred Appellants’ current claim because the 1976 proceeding addressed the mineral interest. The court then granted summary judgment in favor of Appellee, concluding that its predecessor acquired title to the mineral interest in the 1976 action, which was not contested by Appellants’ predecessors. The Supreme Court affirmed, holding (1) the district court properly ruled that Appellants were barred from asserting that they owned the mineral interest; and (2) this dispute did not present an appropriate case for the application of laches. View "Clay v. Mountain Valley Mineral Ltd. P’ship" on Justia Law

Malcolm and French Wallop created an estate plan with the intention of owning and operating the Canyon Ranch and establishing a means of transferring its ownership and operation to their respective children. The estate plan led to the formation of the Wallop Family Limited Partnership (WFLP), which owned and operated the Canyon Ranch. Malcolm and French also formed Wallop Canyon Ranch, LLC (WCR) to serve as the general partner of the WFLP. Scott Goodwyn, individually, as a limited member in the WFLP and derivatively on behalf of the WFLP, sued Malcolm Wallop, WCR, the WFLP, and other Wallop family members, alleging breaches in the ownership, operation, and management of the WFLP. The district court (1) found generally in favor of Goodwyn on his claims relating to gifts made to him and other limited partners; (2) found generally against Goodwyn on his claims of breach of fiduciary duties by certain defendants; and (3) determined that the gifting issues upon which Goodwyn prevailed were derivative claims and that Goodwyn was entitled to reasonable attorney’s fees relating to the derivative claims. The Supreme Court affirmed, holding that the district court did not err in (1) awarding attorney’s fees; and (2) denying Goodwyn’s claims of breach of fiduciary duties by certain defendants. View "Goodwyn v. Wallop" on Justia Law

The child in this case was twelve years old and in sixth grade when an educational neglect case was filed alleging that Father and Mother had “failed or refused to provide adequate education necessary for the child’s well being.” A consent decree was entered pursuant to which the child was to remain in his parents’ custody and the child and parents were to fulfill numerous behavioral and counseling conditions. One of those conditions was that Father and Mother obtain an alcohol/substance abuse evaluation and follow the regimen of treatment recommended. The State later moved to revoke the consent decree due to Mother’s consumption of alcohol. The juvenile court revoked the consent decree and reinstated the neglect proceedings. The Supreme Court reversed and dismissed the case, holding that the juvenile court (1) did not lose jurisdiction over the neglect case after finding that the child’s education problems had been resolved; but (2) erred in concluding that Mother violated the terms of the consent decree by drinking alcohol. View "In re CDR" on Justia Law

The parties in this case had a minor child but never married. After the parties separated, they eventually entered into a settlement agreement agreeing that they would have joint legal custody of the child and that Father would have visitation. The district court approved that agreement. Father filed a request for relief to establish visitation with his child, asserting that no visitation with the child had been scheduled for the upcoming summer in contravention of the parties’ agreement. After a hearing, the district court issued an order establishing a graduated visitation schedule. The Supreme Court affirmed, holding (1) the district court did not err in deciding to exclude testimony relating to particular incidents of domestic abuse that occurred prior to entry of the settlement agreement and properly considered testimony relating to alleged incidents of domestic abuse and child abuse in determining the best interests of the child; and (2) the issue of whether the district court violated Mother’s constitutional right to travel was moot. View "CL v. ML" on Justia Law

Appellant pled guilty to second degree murder and was sentenced to serve seventy-five years to life in prison. On appeal, Appellant contended that the district court considered improper evidence in determining his sentence. Applying plain error review, the Supreme Court affirmed, holding (1) the district court did not err by considering during sentencing statements from individuals who did not meet the statutory definition of victim; and (2) the trial court did not err in allowing the State to present evidence at sentencing that Appellant claimed was in violation of Wyo. R. Crim. P. 32. View "Town v. State" on Justia Law

Plaintiff was a passenger in a vehicle involved in a two-vehicle collision. Plaintiff filed a complaint against both drivers (Defendants) alleging negligence. Before trial, Defendants filed a notice of their admission of liability admitting that they were equally at fault in causing the collision. However, Defendants continued to contest damages. During trial, Plaintiff asked the jury to award damages in the range of $164,000 to $184,000. The jury returned a verdict awarding Plaintiff $80,000. Plaintiff appealed, claiming that the district court committed several errors in its trial and post-trial rulings. The Supreme Court affirmed, holding that the district court committed no reversible error in its rulings. View "Stocki v. Nunn" on Justia Law

After Mother and Father divorced in 2010, the parties shared custody of their minor children. Father later petitioned for custody modification, alleging that there had been a “material change in circumstances” since the entry of the original custody order, chief among them being Mother’s arrest for conspiracy to commit larceny by bailee. Mother counterclaimed, also alleging that a material change in circumstances had occurred in part because of Father’s changed living situation. Both parties sought primary custody. The district court ruled that there had been a material change in circumstances warranting reopening the custody determination and awarded primary custody of the children to Mother. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in finding that a material change in circumstances existed that warranted the reopening of the existing custody order; and (2) the district court did not abuse its discretion in finding that it was in the best interests of the children for Mother to have primary custody. View "Dahlke v. Dahlke" on Justia Law

Appellant submitted a bid for a highway project in Sublette County, Wyoming and was the low bidder. The Board of County Commissioners of Sublette County awarded the contract to another bidder, a contractor that was from Sublette County. Appellant filed a complaint in the district court alleging that by not entering into the contract with Appellant, the Commissioners violated Wyo. Stat. Ann. 16-6-102(a). The district court found in favor of the Commissioners on all claims. On appeal, the Supreme Court held section 16-6-102(a) inapplicable and remanded the case for a determination of whether the award was appropriate. On remand, the district court held generally in favor of the Commissioners, finding that the Commissioners’ award was within their discretion and appropriate. The Supreme Court reversed, holding that the Commissioners’ utilization of an undisclosed preference for Sublette County contractors in awarding the public contract opened for competitive bid constituted an illegal exercise of discretion. Remanded for a determination of damages. View "W. Wyo. Constr. Co., Inc. v. Bd. of County Comm’rs" on Justia Law

Buyer agreed to purchase a portion of a 2,700 acre ranch from Sellers. Sellers agreed to finance a portion of the purchase price by accepting Buyer’s promissory note. After Buyer defaulted on the promissory note, Sellers initiated foreclosure proceedings. Buyer and its successor in interest (collectively, Buyers) filed a complaint for declaratory judgment and a motion for a temporary restraining order to halt the foreclosure, asserting several causes of action. Sellers counterclaimed, asserting that Buyers breached the terms of the promissory note. The district court granted summary judgment in favor of Sellers. Both parties appealed. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in granting summary judgment in favor of Sellers with respect to Buyers’ adverse possession claim and with respect to Sellers’ breach of contract claim; and (2) erred in denying Sellers’ request for attorney’s fees. Remanded. View "Flynn v. Ruby River Canyon Ranch, Ltd." on Justia Law