Justia Wyoming Supreme Court Opinion Summaries

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

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