Justia Wyoming Supreme Court Opinion Summaries

Vernon Bailey injured his neck and back while working as a custodial supervisor. The Wyoming Workers’ Compensation Division awarded benefits to Bailey. When Bailey’s symptoms did not improve, a neurosurgeon requested preauthorization for a recommended discectomy and fusion because of neck pain. The Division denied the request. After a hearing, the Medical Commission upheld the Division’s denial of benefits for Bailey’s surgical spine issues. The district court affirmed the Medical Commission. The Supreme Court affirmed, holding that substantial evidence existed to support the Medical Commission’s decision to deny Bailey further benefits for his cervical spine injury. View "Bailey v. State ex rel., Dep’t of Workforce Servs." on Justia Law

Christopher Walton and Tammara Duhn hired Jacob Hatch and his construction company (collectively, Hatch) as the general contractor to build a custom home in a subdivision. Hatch drew up two proposed written contracts, but Walton and Duhn would not sign either one. Nevertheless, construction began. A dispute over what Walton and Duhn owed Hatch led Hatch to terminate his involvement in the project before the house was finished. Walton and Duhn sued Hatch for breach of contract, among other claims. The district court entered judgment in favor of Walton and Duhn and awarded damages. The Supreme Court reversed in part and affirmed in part, holding that the district court (1) erred in calculating the damages that Walton and Duhn suffered as a result of Hatch’s improper billing practices; (2) erred in finding liability and awarding damages for breach of an implied warranty that the home would be built in a skillful and workmanlike manner; and (3) did not abuse its discretion in denying Walton’s and Duhn’s application for attorney fees. View "Walton v. Hatch" on Justia Law

After a jury trial, Appellant was found guilty of second-degree murder for shooting and killing his cousin. Appellant was also found guilty of kidnapping-confinement and first-degree sexual assault relating to conduct involving his cousin’s girlfriend. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it instructed the jury that it could presume malice from the use of a deadly weapon; and (2) the district court did not err in denying Appellant’s motion to sever the second-degree murder charge from the other charges of kidnapping and sexual assault. View "Hereford v. State" on Justia Law

Plaintiff, an eighth grade student at a junior high school, was injured when she slipped and fell in the locker room of the junior high school. Plaintiff filed suit against the School District claiming that the it had negligently failed to operate and maintain the junior high school building in a reasonably safe condition. The district court entered judgment in favor of the School District. Both parties appealed. Plaintiff challenged the district court’s judgment in favor of the School District, and the School District challenged the court’s denial of its motion for summary judgment. The Supreme Court (1) affirmed the district court’s judgment in favor of the School District, holding that the district court did not err in concluding that Plaintiff failed to carry her burden of proving the existence of a dangerous condition or that the School District did not exercise ordinary care in maintaining the building; and (2) declined to review the court’s ruling on summary judgment. View "Halvorson v. Sweetwater County School Dist." on Justia Law

Appellant pleaded guilty to attempted second-degree murder. The district court accepted Appellant’s guilty plea and sentenced him to not less than twenty-five and no more than fifty years incarceration. After unsuccessfully moving to withdraw his guilty plea and filing a petition for post-conviction relief, Appellant filed a Wyo. R. Crim. P. 35(b) motion for sentence reduction, requesting that his sentence be reduced to fifteen to twenty-five years. The district court denied the motion. The Supreme Court affirmed, holding that Appellant failed to overcome his burden of proving that the district court abused its discretion in denying his Rule 35(b) motion. View "Chapman v. State" on Justia Law

While working as the municipal court judge for the town of Diamondville, Wyoming, Appellant slipped and fell on the icy outdoor steps of the town hall. Due to pain in her lower back, Appellant underwent back surgery in 2009. The Wyoming Workers’ Safety and Compensation Division paid for this surgery, along with temporary disability benefits. In 2011, Appellant experienced acute onset of pain in her lower back and left leg. Appellant underwent surgery for a herniated disk. The Division denied coverage for the second surgery, as well as temporary total disability benefits, on the basis that the recent back surgery was not directly related to the work injury. The Office of Administrative Hearings upheld the decision. The district court affirmed. The Supreme Court affirmed, holding that the hearing officer’s decision to deny benefits was supported by substantial evidence and that Appellant failed to show that the decision was arbitrary, capricious, or not in accordance with law. View "Newman v. State ex rel., Dep’t of Workforce Servs." on Justia Law

In 1920, the Beckton Ranch Trust (BRT) was formed by members of the Forbes family to hold parcels of land in Sheridan County, Wyoming and their appurtenant water and ditch rights for the benefit of their descendants. In 2007, Waldo Forbes (Spike) resigned as trustee after a dispute with his siblings. Later that year, the remaining trustees - Spike’s brother, Cam, and his sisters, Julia, Sarah, and Edith - began a series of land and water transactions. Spike subsequently sought the removal of the trustees. The district court (1) concluded that Cam and Julia had breached their duty of loyalty and should be removed as BRT trustees; and (2) made no finding as to Sarah and Edith, and therefore, they continued as BRT trustees.The Supreme Court reversed in part and affirmed in part, holding (1) Cam and Julia breached their duty of loyalty, but because the evidence did not demonstrate that they acted dishonestly or with want of capacity, or that any serious harm had been done, the breaches did not warrant their removal as trustees; and (2) the district court correctly decided not to remove Sarah and Edith. View "Forbes v. Forbes" on Justia Law

After purchasing their property, William and Tia Hansuld notified Lariat Diesel Corporation and Marvin Piel (collectively, “Lariat”) that it could not longer use their property for access. Litigation ensued. This matter was the third appeal of the parties’ various claims to the Supreme Court. In Hansuld I, the Court concluded that Lariat had an implied easement for access across the Hansulds’ property. On remand from Hansuld II, the district court conducted a bench trial to establish the specific location of Lariat’s implied access easement. The district court applied the law of floating easements to determine the location of Lariat’s implied access easement and accepted one of Lariat’s proposed locations with some modification. The Supreme Court affirmed, holding (1) the district court incorrectly recited the law pertaining to floating easements, but the error did not make a legal difference; and (2) the Hansulds did not demonstrate that the district court’s final decision as to the location of the implied easement was either clearly erroneous or that the court erred as a matter of law. View "Hansuld v. Lariat Diesel Corp." on Justia Law

Plaintiffs were several residents in the Milatzo Subdivision who sought to permanently enjoin Defendants from operating a daycare business out of their residence in the Subdivision. The district court granted Plaintiffs’ request for a permanent injunction, concluding (1) Defendants’ daycare operation violated the protective covenants governing properties in the Subdivision, (2) Defendants did not establish that those covenants had been abandoned, and (3) the violation harmed Plaintiffs. The Supreme Court affirmed, holding that the district court did not err in finding that the protective covenants governing the Subdivision were not abandoned and that Defendants flagrantly ignored the covenants when they opened their daycare operation. View "Moore v. Wolititch" on Justia Law

Jerome Knight, who was employed by M&M Welding Services, LLC, and his supervisor, Victory McCoy, who was one of the owners of M&M, were killed in an automobile accident. McCoy was driving the vehicle when the accident occurred. Plaintiff, as Decedent’s personal representative, filed a wrongful death action against the McCoy Estate and M&M. The district court granted summary judgment as to claims against M&M on grounds of employer immunity under the Wyoming Worker’s Compensation Act. The court then granted summary judgment in favor of the McCoy Estate on grounds of defective service of process, lack of personal jurisdiction, and expiration of the statute of limitations. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) correctly concluded that M&M’s employer immunity under the Wyoming Worker’s Compensation Act barred Plaintiff’s wrongful death action against M&M; but (2) erred in determining that Plaintiff’s action against the McCoy Estate was barred by the statute of limitations. View "Knight v. Estate of McCoy" on Justia Law