Justia Wyoming Supreme Court Opinion Summaries
Adekale v. State
After a jury trial, Defendant was found guilty of fifteen counts of felony Medicaid fraud and one count of misdemeanor Medicaid fraud. Defendant appealed, arguing, among other things, that the State failed to present sufficient evidence that he provided “medical assistance” to Medicaid recipients as defined in the relevant statute. The Supreme Court affirmed in part and remanded in part, holding that the district court (1) did not abuse its discretion in denying Defendant’s motion for judgment of acquittal because the State produced sufficient evidence that Defendant provided “medical assistance”; (2) did not err in instructing the jury; but (3) erred in its sentence on one of the counts. Remanded for resentencing. View "Adekale v. State" on Justia Law
Posted in:
Criminal Law
Redland v. Redland
At issue in this case was the Redland family’s dispute over ranch property that some Redland children (“Children”) claimed that their father (“Father”) agreed to place in a family trust. In the first appeal, the Supreme Court concluded that the district court erred in entering summary judgment, as questions of fact existed on the issues of whether Children’s claims against Father were barred by the statute of frauds and the statute of limitations. On remand, the district court determined that Children’s claims were not barred and ordered that the disputed property, with the exception of property on which Father resided (“residential property”), be immediately transferred to the family trust. With regard to the residential property, the court ordered that the property be transferred to the trust upon Father’s death. The Supreme Court affirmed as modified, holding that the district court (1) did not err in holding that an enforceable agreement existed that required placing the disputed property in the trust; (2) did not err in determining that the statute of limitations did not bar Children’s claims; and (3) erred in its disposition of the residential property. Remanded with directions that the residential property be immediately transferred to the family trust subject to Father’s life estate in the property. View "Redland v. Redland" on Justia Law
Montana Food, LLC v. Todosijevic
Milan Todosijevic and Daniel Vokov each owned a fifty percent interest in Montana Food, LLC. Vukov unilaterally adjusted the ownership interests to reflect a 99.7 percent interest in him and a .28 interest in Todosijevic. Todosijevic sued Vukov and the LLC, claiming that Vukov did not have the authority to adjust the members’ ownership interests. The district court granted summary judgment for Todosijevic, concluding that, as a matter of law, Vukov did not have the authority to adjust the ownership interests. The Supreme Court affirmed, holding that the district court did not err in ruling that Vukov had no authority to unilaterally adjust the members’ ownership interests. View "Montana Food, LLC v. Todosijevic" on Justia Law
Posted in:
Business Law
EL v. State, Dep’t of Family Servs.
Following Appellant’s default and after a default hearing, the district court terminated Appellant’s parental rights to three minor children. Appellant appealed. Appointed counsel filed a motion to withdraw as counsel and an Anders brief, arguing that he could “find no basis whatsoever to advance an argument of any merit.” The Court granted the motion. The Court then notified Appellant that the district court’s order terminating parental rights would be affirmed unless Appellant filed a brief persuading the Court that the appeal was not wholly frivolous. After Appellant filed his “brief letter,” the Supreme Court ordered that the district court’s order terminating parental rights be affirmed, as the letter presented no cogent legal argument. View "EL v. State, Dep’t of Family Servs." on Justia Law
Posted in:
Family Law
Lindstrom v. State
After a jury trial, Defendant was found guilty of three counts of first degree sexual abuse of a minor and three counts of second degree sexual abuse of a minor for acts involving two victims. Defendant was also found guilty of two counts of aggravated assault and two counts of first degree sexual assault for acts involving an adult victim. The Supreme Court affirmed the convictions, holding (1) the district court erred when it allowed the State to introduce un-noticed character evidence, but the error was harmless; (2) the State's amendment to the information did not prejudice Defendant’s substantial rights; and (3) Defendant was not denied his right to a fair trial due to prosecutorial misconduct. View "Lindstrom v. State" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Turner v. State
Defendant was charged with escape from official detention. Defendant later filed a motion to dismiss the escape charge due to an alleged failure to bring him to trial within the time limits contained in Wyoming’s Interstate Agreement on Detainers (IAD) statute. The district court denied the motion to dismiss. Appellant subsequently entered a conditional guilty plea, reserving his right to appeal the denial of his motion to dismiss. The Supreme Court affirmed, holding that the speedy trial provisions of the IAD did not require that the charge against Defendant be dismissed because the IAD did not apply in this case. View "Turner v. State" on Justia Law
Posted in:
Criminal Law
Basic Energy Servs., LP v. Petroleum Res. Mgmt., Corp.
PRM Partners was a leaseholder of lands which covered an oil well. PRM Partners designated Petroleum Resource Managements, Corp. (PRM) as the operator of the well. PRM contracted with Hot Oil Services, Inc. to perform the day-to-day operations of the well. In 2009, Hot Oil requested that Basic Energy Services, LP perform workover operations on the well. While Basic Energy was performing the workover operations, a fire erupted, which damaged various pieces of equipment, including Basic Energy’s workover rig. Basic Energy sued PRM Partners and PRM to recover the damage to its equipment. The district court granted summary judgment for PRM Partners and PRM, concluding that Hot Oil was an independent contractor and that neither PRM nor PRM Partners could be held liable for the acts of an independent contractor. The Supreme Court (1) reversed and remanded on the issue of whether PRM breached the contract and reversed and remanded on the claim that PRM acted negligently in hiring Hot Oil, holding that the district court erred in entering summary judgment on these issues, as PRM failed to carry the initial burden of a summary judgment movant; and (2) ordered that PRM Partners be dismissed from the appeal. View "Basic Energy Servs., LP v. Petroleum Res. Mgmt., Corp." on Justia Law
Posted in:
Energy, Oil & Gas Law, Injury Law
Loran v. Loran
In 2013, the district court entered a divorce decree dissolving the marriage of Mother and Father. The court awarded primary custody to Mother and awarded Father liberal visitation. Mother later filed a motion seeking relief from the order awarding visitation under Mont. R. Civ. P. 60(b)(1). The district court denied the motion and also awarded joint presumptive child support. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not abuse its discretion in denying the child custody and visitation arrangement aspect of Mother’s motion; but (2) the district court erred by ordering joint presumptive child support without determining that both parties contribute substantially to the children’s expenses as required by Wyo. Stat. Ann. 20-2-304(c). Remanded. View "Loran v. Loran" on Justia Law
Posted in:
Family Law
DRW v. DLP
Appellant was that father of ARW. Appellees were a couple who were involved in ARW’s life since she was three weeks old. Both Appellant and ARW’s mother executed powers of attorney providing that Appellees could have physical custody of ARW. ARW’s mother subsequently consented to termination of her parental rights and to adoption by Appellees. After Appellant was charged with two counts of sexual abuse of ARW’s friend, Appellees were appointed permanent guardians for ARW without Appellant’s consent. Appellant was convicted, and Appellees initiated this action terminate Appellant’s parental rights. After a hearing, the district court entered an order terminating Appellant’s parental rights. The Supreme Court affirmed, holding that the district court (1) did not err in concluding that the Indian Child Welfare Act did not apply to the termination proceedings; (2) did not err in denying Appellant’s motion to set aside the entry of default against him; and (3) properly concluded that Appellees presented sufficient evidence that DRW was unfit to have care and custody of ARW. View "DRW v. DLP" on Justia Law
Posted in:
Family Law
L & L Enterprises v. Arellano
Appellee was injured while on the job and made a workers’ compensation claim. The Wyoming Division of Workers’ Compensation denied Appellee’s claim for coverage. Appellee later admitted that he provided false documentation in order to secure his employment, that he was a citizen of Mexico, and that he didn’t know if he had permission to work in the United States. After a contested case hearing, the Office of Administrative Hearings (OAH) denied benefits on the grounds that Appellee was not an “employee” as defined in Wyoming’s workers’ compensation statutes. The district court reversed the OAH and awarded Appellee benefits, concluding that the denial of Appellee’s claim for benefits was arbitrary, capricious, an abuse of discretion or otherwise not in accordance with law. The Supreme Court affirmed, holding that the district court did not err in concluding that the OAH’s action was not in accordance with the law and in awarding benefits. View "L & L Enterprises v. Arellano" on Justia Law