Justia Wyoming Supreme Court Opinion Summaries

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

The parties in this case owned interests in certain oil and gas leases in Sublette County, Wyoming. In the underlying litigation, the district court granted a monetary judgment against Defendants for amounts due to Plaintiffs. Defendants paid the monetary judgment. Plaintiffs subsequently filed a motion to enforce judgment, claiming that Defendants were not properly accounting to them as required by the prior declaratory judgment and a net profits contract (NPC). After the district court issued its judgment, Defendants appealed the court’s decisions on the merits and its order requiring Defendants to pay attorney fees. The Supreme Court affirmed as revised, holding that the district court (1) properly assumed jurisdiction over the issues presented; (2) correctly interpreted its prior judgment and Defendants’ accounting responsibilities under the NPC; and (3) properly granted Plaintiffs’ request for attorney fees with one minor exception. View "Ultra Resources, Inc. v. Hartman" on Justia Law

Defendant pleaded guilty to one count of welfare fraud. Consistent with the plea agreement, the district court imposed a three to eight year sentence and ordered that Defendant pay $90,723 in restitution. Defendant appealed, arguing that it was not reasonable for the district court to order her to pay the entire restitution amount when it was clear from the record that she would be unable to pay it. The Supreme Court affirmed the district court’s restitution order, holding that, under the circumstances, the district court’s failure to find that Defendant had no ability to pay was not unreasonable, and its failure to find that no reasonable probability existed that she would have the ability to pay in the future was not unreasonable. View "Shafer v. State" on Justia Law

Pursuant to a plea agreement, Appellant pled guilty of charges of conspiracy to deliver methamphetamine and endangering a child. As part of the plea agreement, Appellant agreed to cooperate with the State in providing information to assist the State in its investigation of other criminal activity. Appellant agreed that, if he did not meet this obligation, he would not object to the State’s motion under Wyo. R. Crim. P. 35(a) for an increase in his sentence. Several months after Appellant was sentenced, the State moved to modify his sentence, asserting that Appellant had breached the plea agreement by failing to cooperate. The district court granted the motion and imposed a new, more severe sentence. The Supreme Court vacated Appellant’s sentence, holding that, despite the parties’ plea agreement, the district court lacked jurisdiction to increase the sentence because Rule 35 does not give the trial court jurisdiction to increase a previously-imposed, legal sentence. Remanded. View "Hamilton v. State" on Justia Law

The year after Mother and Father were married, Mother filed a complaint for divorce. The next year, the district court entered an order enforcing the parties’ settlement agreement. Thereafter, Father filed a motion asking the district court to enter a divorce decree and attached a proposed decree. Mother submitted her own proposed decree. The district court approved and entered Father’s proposed decree, finding that that decree followed more closely the terms of the settlement. The decree awarded Father primary residential custody of the parties’ minor daughter and calculated child support. The Supreme Court affirmed the divorce decree in all respects except the provision requiring Mother to pay retroactive child support, holding (1) Father was not estopped from claiming the settlement agreement was binding when he previously took the position that it was not; (2) the district court did not err in enforcing the settlement agreement where the court concluded that the parties’ agreement was in the child’s best interest; (3) the district court did not err in failing to apply the joint presumptive child support found in Wyo. Stat. Ann. 20-2-304(c); and (4) district court erred in ordering Mother to both reimburse Father for travel costs and to pay retroactive child support. View "Wright v. Wright" on Justia Law

Husband filed for divorce from Wife in 2012. After a trial, the district court issued a decree of divorce dividing the parties’ real property and other significant assets of the parties. Wife appealed, asserting that the district court’s bias toward her deprived her of a fair trial and that the district court’s division of the marital property was so inequitable as to shock the conscience. The Supreme Court affirmed the divorce decree, holding (1) the district court did not show bias towards wife during the divorce trial; and (2) the district court’s overall property division was appropriate. View "Guy-Thomas v. Thomas" on Justia Law

Plaintiff filed a complaint alleging that she had been injured when she was a passenger in a vehicle driven by Defendant that left the road and rolled several times. Plaintiff served Defendant under Wyoming’s nonresident motorist statute by serving the Secretary of State and sending a copy by certified mail to Defendant at a Rock Springs, Wyoming address. However, Plaintiff had obtained a more current address in discovery in a prior proceeding. The district court quashed the attempted service and dismissed the case as untimely, concluding that Plaintiff failed to demonstrate due diligence in locating Defendant. The Supreme Court affirmed, holding (1) Plaintiff failed to exercise due diligence when she mailed notice of service to an address which she knew or and therefore, the attempted notice of the suit to Defendant did not satisfy the requirements of Wyoming’s nonresident motorist statute; and (2) service on Defendant’s former attorney did not satisfy the statute’s requirements. View "Dirks v. Jimenez" on Justia Law

The three petitioners in this case (collectively, “Petitioners”) were held in the Fremont County Detention Center on unrelated criminal charges. None of the Petitioners were able to post the cash-only bail imposed by the lower courts as a condition of their pretrial release. As a result, each Petitioner remained in jail pending trial. Each Petitioner filed a petition to the Supreme Court for habeas corpus relief seeking immediate release from the detention center and requesting a determination that cash-only bail is impermissible under the Wyoming Constitution and Rules of Criminal Procedure. The Supreme Court consolidated the petitions for review and affirmed the lower courts’ use of cash-only bail, holding that cash-only bail does not violate Wyo. Const. art. I, 14 or Wyo. R. Crim. P. 46.1. View "Saunders v. Hornecker" on Justia Law

Appellant and Appellee were the brother and sister of William Bratton. Appellee was appointed as guardian for William in June 2012. In July 2012, Appellant withdrew $10,000 from a bank account held jointly with Appellee for the benefit of William and transferred the funds to an account held individually by Appellant. Appellant was subsequently ordered to return the funds. Thereafter, Appellee moved to release the funds to a conservatorship account to be administered by Appellee as conservator. The district court ultimately granted the motion. The Supreme Court affirmed, holding that the district court (1) did not err by granting Appellee’s motion to release funds; (2) did not err by vacating the initially scheduled hearing on Appellee’s motion to release funds; and (3) had the authority to rule on the motion to release funds. View "Bratton v. Blenkinsop" on Justia Law