Justia Wyoming Supreme Court Opinion Summaries

Plaintiff filed a complaint against Defendant, her former employer, alleging harassment, emotional stress, personal injury, loss of income, and age discrimination. The district court dismissed the complaint for lack of subject matter jurisdiction and for failure to state a claim. The Supreme Court affirmed, holding (1) the district court correctly dismissed Plaintiff’s discrimination and harassment claims where she not only failed to allege timely satisfaction of the statutory jurisdictional conditions precedent but failed to timely comply with the jurisdictional conditions precedent; and (2) the district court properly dismissed Plaintiff’s state law tort claims. View "Apodaca v. Safeway, Inc." on Justia Law

In 2007, Employee suffered compensable work injuries. Five years later, Employee sought worker’s compensation benefits to cover medical expenses related to his chronic obstructive pulmonary disease (COPD). The Wyoming Workers’ Compensation Division denied benefits on the basis that the COPD was unrelated to Employee’s work injuries. The Office of Administrative Hearings (OAH) upheld the denial of benefits, concluding that Employee’s COPD was a preexisting condition and that Employee had not met his burden of showing that his work injuries materially aggravated his preexisting COPD. The district court affirmed. The Supreme Court reversed, holding that the OAH’s conclusions were not supported by substantial evidence. Remanded for entry of an order awarding benefits. View "Vandre v. State ex rel. Dep’t of Workforce Servs." on Justia Law

After a jury trial, Defendant was convicted of first-degree sexual assault and two counts of third-degree sexual abuse of a minor. Defendant was sentenced as a habitual criminal to life imprisonment on the first-degree sexual assault conviction and two thirteen- and fifteen-years on the remaining two charges, to be served concurrently to each other and to the life sentence. The Supreme Court affirmed, holding (1) Defendant was serving in a position of authority over the victim; (2) Defendant was correctly charged; (3) the district court did not violate any rule of law by not merging Defendant’s convictions and sentences; and (4) Defendant was properly sentenced as a habitual criminal. View "Rogers v. State" on Justia Law

After a jury trial, Defendant was convicted of sexual abuse of a minor in the second degree. Defendant appealed, asserting that his trial attorney committed a number of errors during the course of the proceedings below, resulting in a violation of his constitutional right to the effective assistance of counsel. The Supreme Court affirmed the judgment and sentence of the district court, holding that Defendant failed to satisfy his burden of demonstrating that he suffered prejudice as a result of his trial counsel’s performance at trial, and therefore, Defendant’s ineffective assistance of counsel claim necessarily failed. View "Galbreath v. State" on Justia Law

Pursuant to a plea agreement, Defendant entered an Alford plea to aggravated assault and battery and to being a habitual offender. The district court sentenced Defendant to twelve to sixteen years of incarceration. Defendant later filed a pro se motion to correct an illegal sentence challenging his sentence enhancement pursuant to the habitual criminal statute. Specifically, Defendant argued that the habitual criminal statute is designed for those who demonstrate a pattern of violent conduct and that the State did not prove a pattern of violent conduct in his case. The district court denied the motion. The Supreme Court affirmed, holding that Defendant’s conduct fell directly within the habitual offender statute, and therefore, the district court properly enhanced his sentence within the enhanced penalty range. View "Harris v. State" on Justia Law

After a jury trial, Defendant was convicted of manslaughter and battery of a household member. Defendant appealed his manslaughter conviction. The Supreme Court affirmed, holding that the trial court did not err in (1) denying Defendant’s post-trial motion for judgment of acquittal in relation to the manslaughter conviction; (2) denying Defendant’s motion for a new trial based upon inadmissible hearsay, as the district court immediately intervened and then gave the jury a curative instruction; (3) refusing to instruct the jury on Defendant’s claim of self-defense; and (4) admitting into evidence the deceased victim’s 911 call. View "Bruce v. State" on Justia Law

Triangle Cross Ranch, Inc. offered help to troubled boys by putting them to work on a cattle ranch that was described as “a Catholic Christian Therapeutic Residential Substance Abuse Treatment Program.” Triangle Cross offered individual counseling and group therapy. The boys’ families paid an admission fee and a monthly tuition. The Wyoming Department of Family Services (DFS) sought an injunction, arguing that Triangle Cross was providing the type of services that required certification, which it had not obtained. After a bench trial, the district concluded that Triangle Cross was offering services that required it to obtain proper licensing and certification and entered an order enjoining Triangle Cross from operating an uncertified child care facility. The Supreme Court affirmed, holding that the district court correctly found that Triangle Cross was offering services to children who are delinquent and thus was required by Wyoming law to obtain certification. View "Triangle Cross Ranch, Inc. v. State" on Justia Law

Dean Hildebrant was working as an HVAC technician at Central Wyoming College in Riverton when he fell from a ladder. The Wyoming Workers’ Safety and Compensation Division found that Hildebrant had suffered a compensable injury as a result of the fall. As part of Hildebrant’s treatment, his doctor recommended the implantation of a spinal cord stimulator in his back. The Division denied preauthorization for the implant. The Office of Administrative Hearings (OAH) upheld the Division’s denial, determining that the implant was premature. The district court affirmed the OAH. The Supreme Court affirmed, holding that there was substantial evidence in the record supporting the OAH’s determination that (1) the proposed treatment was causally related to Hildebrant’s compensable injury, and (2) implantation of a spinal cord stimulator was not medically necessary. View "Hildebrant v. State ex rel., Dep’t of Workforce Servs." on Justia Law

This dispute concerned injuries sustained by Steven Johnson when he fell off a haystack while helping his father feed cattle on property owned by the Dale C. and Helen W. Johnson Family Revocable Trust. Steven and his wife (together, Appellants) sued the Trust, a co-trustee, and a successor co-trustee (collectively, Appellees), claiming that Appellees were negligent in a number of respects. The district court granted summary judgment for Appellees, concluding that the Trust owed Steven no duty of care. The Supreme Court affirmed, holding that even if the Trust owed Steven the duty to exercise reasonable care, the negligence claim could not survive because no reasonable fact finder could conclude that the Trust acted unreasonably or breached a duty to Steven. View "Johnson v. Dale C. & Helen W. Johnson Family Revocable Trust" on Justia Law

Mary Wise was involved in a single car collision in which she was the passenger and Steven Ludlow was the driver. Wise subsequently filed suit against Ludlow. The jury returned a verdict finding Ludlow negligent, that his negligence was a cause of Wise’s injuries or damages, and that Ludlow was fifty-five percent at fault and Wise was forty-five percent at fault. Wise appealed, and Ludlow cross-appealed. The Supreme Court affirmed, holding that the district court did not err (1) by instructing the jury on comparative fault; (2) in excluding evidence of Wise’s lack of financial resources to explain delays in seeking treatment for her injuries; (3) by admitting the testimony of Ludlow’s expert witness; (4) in denying Wise’s attempt to impeach Ludlow’s testimony with his answer to the complaint; and (5) in determining that it had personal jurisdiction over Ludlow. View "Ludlow v. Wise" on Justia Law