Justia Wyoming Supreme Court Opinion Summaries

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

In this child neglect proceeding, the juvenile court found that it was in the child’s best interest to cease efforts to reunify him with Mother and to change the permanency plan to termination of parental rights and eventually adoption. The Supreme Court affirmed the juvenile court’s order, holding (1) while due process may require an evidentiary hearing when a permanency plan is changed from family reunification to termination of parental rights, Mother failed to establish plain error in the juvenile court’s failure to apply the Wyoming Rules of Evidence during the permanency hearing; and (2) sufficient evidence supported the juvenile court’s finding that to find that it was in the child’s best interests to change the permanency plan to adoption. View "In re GC" on Justia Law

Accelerated Receivable Solutions (ARS) filed a creditor’s claim against the Estate of Margaret A. Hauf (Estate). The Estate rejected ARS’s claim, filed the notice of rejection in district court, and mailed the rejection notice to ARS via certified mail. The mailed notice was returned to the Estate unclaimed. Approximately four months later, counsel for ARS learned that the postal service had erroneously stamped the the certified mailing unclaimed and returned it to the sender. ARS filed a complaint in district court objecting to the disallowance of its claim and seeking judgment on the claim. The district court dismissed the complaint as time barred. The Supreme Court affirmed, holding that the district court did not err in dismissing ARS’s complaint against the Estate where the Estate strictly complied with the statutory notice requirements in rejecting ARS’s claim and where ARS failed timely to file its complaint after receiving constitutionally adequate notice of the Estate’s rejection of ARS’s claim. View "Accelerated Receivable Solutions v. Hauf" on Justia Law

Defendant pleaded guilty to one count of second degree sexual abuse of a minor. The district court sentenced Defendant to five to ten years of incarceration but suspended the sentence and ordered him to serve six years on supervised probation. After Defendant was released on probation, the State petitioned to revoke Defendant’s probation, alleging several violations of the conditions of his probation. After a hearing, the district court revoked Defendant’s probation. The Supreme Court affirmed, holding that the district court (1) did not commit reversible error by failing to make an express finding that Defendant’s probation condition violations were willful; and (2) did not abuse its discretion by revoking Defendant’s probation. View "Miller v. State" on Justia Law

Sheridan Newspapers, Inc. filed a petition requesting release of minutes reflecting discussion by the Board of Trustees of Sheridan County School District #2 of a proposed multi-purpose recreational facility during executive sessions. In response, the Board asserted that the executive sessions were allowed under the Wyoming Public Meetings Act (WPMA), and the minutes were confidential. After reviewing the minutes in camera the district court entered an order granting summary judgment for the Board, concluding that all issues discussed by the Board during executive session were within the framework of what may be kept confidential pursuant to the WPMA. The Supreme Court reversed, holding that the minutes were so vague as to reveal virtually nothing about the Board’s discussions during executive sessions, and therefore, the minutes were not entitled to confidential treatment. Remanded. View "Sheridan Newspapers, Inc. v. Bd. of Trs." on Justia Law

Prior to giving birth to a child conceived with Father, Mother stopped communicating with Father. After learning about his child’s birth on Facebook, Father filed a petition to establish paternity, custody, visitation and child support. After a trial, the district court awarded Mother primary custody subject to Father’s visitation. Father appealed, arguing that the district court abused its discretion when it awarded primary custody of the child to Mother. The Supreme Court affirmed, holding that the district court did not abuse its discretion or commit reversible error in deciding to award primary custody to Mother. View "FFJ v. ST" on Justia Law

After a jury trial, Defendant was found guilty of three counts of delivery of cocaine. The Supreme Court reversed the conviction and remanded for a new trial, holding (1) the evidence was sufficient to support the conviction; (2) Defendant was not denied his right to confrontation when law enforcement officers testified about results of tests conducted by others; (3) the prosecutor did not commit misconduct; but (4) Defendant’s trial counsel rendered ineffective assistance by failing to object to improper testimony and argument, by failing to demand notice of Wyo. R. Crim. P. 404(b) evidence and enter an objection to the testimony, and by failing to request that audio tapes of controlled buys be played in their entirety, and Defendant was prejudiced by counsel’s deficient performance. View "Fennell v. State" on Justia Law

After a jury trial, Appellant was convicted of second-degree murder. On appeal, Appellant argued that the jury was not properly instructed on the element of malice under the Court’s decision in Wilkerson v. State, which was issued after Appellant’s conviction. The Supreme Court affirmed, holding that because Appellant failed to show a reasonable probability that he would have received a more favorable verdict had the jury been instructed in accordance with Wilkerson, Appellant did not show that the instructional error resulted in material prejudice to him, and therefore, there was no plain error in the jury instructions. View "Miller v. State" on Justia Law

Defendant entered a conditional plea to possession of marijuana with intent to deliver and possession of methamphetamine with intent to deliver. Defendant was sentenced to two consecutive sentences of seven to ten years and fourteen to eighteen years. The Supreme Court affirmed. After unsuccessfully seeking a sentence reduction, postconviction relief, and habeas relief, Defendant filed a motion to correct an illegal sentence, arguing that his sentences violated double jeopardy. The district court denied the motion on the basis of res judicata. The Supreme Court affirmed, holding that Defendant’s claims were barred by res judicata. View "Tucker v. State" on Justia Law