Justia Wyoming Supreme Court Opinion Summaries

Following Defendant’s involvement in an automobile accident, law enforcement officers searched Defendant’s vehicle and found marijuana. Defendant was subsequently charged with felony possession of marijuana. Defendant moved to suppress the evidence obtained in the search of his vehicle as well as his statements to law enforcement, arguing that the investigating officer impermissibly extended the scope of his detention. The district court denied the motion to suppress. Thereafter, Defendant pleaded guilty to the charge, reserving the right to appeal the court’s order denying his motion to suppress. On appeal, instead of challenging the search of his vehicle, Defendant argued that the State failed to present sufficient evidence at the suppression hearing concerning the certification of the drug dog used by the investigating officer to conduct a free-air sniff outside Defendant’s vehicle. The Supreme Court affirmed, holding that in entering his conditional plea, Defendant did not properly reserve any questions concerning the reliability of the drug dog, and therefore, that issue may not be addressed here. View "Ward v. State" on Justia Law

Appellant, the manager of the Dubois branch of the Fremont County Library System (FCLS), used an FCLS account to order books for the Dubois school system. The FCLS executive director terminated Appellant, determining that Appellant had improperly used FCLS funds to purchase books for the District. The FCLS Board of Trustees upheld the termination based upon an erroneous belief that Appellant had violated Wyo. Stat. Ann. 9-13-105. The district court affirmed, concluding that the Board misread section 9-13-105 but that because Appellant’s employment was at-will, Appellant’s employment may be terminated at any time with or without cause. The Supreme Court affirmed, holding that, as an at-will employee, Appellant did not have a property interest in continued employment or a right to a contested case hearing. View "Sabatka v. Bd. of Trs. of the Fremont County Pub. Library Sys." on Justia Law

After Mother was told by her nine-year-old son, GT, that Father, who served in the United States Air Force (USAF,) was watching GT shower, Mother arranged for GT to see a Counselor. Counselor reported to law enforcement and then USAF authorities regarding the suspected child abuse. After the USAF authorities completed their investigation, they concluded that the preponderance of the evidence did not support further action. Father filed a defamation complaint, alleging that Mother and Counselor made intentionally malicious and baseless allegations of sexual abuse to law enforcement and USAF authorities. The district court granted summary judgment for Mother and Counselor, concluding that the defendants acted in good faith in reporting the allegations. The Supreme Court affirmed, holding that Father failed to demonstrate a genuine issue of material fact existed with respect to immunity that (1) Counselor acted in bad faith under the child abuse reporting statute, and (2) Mother made false statements to parties outside the scope of the child abuse investigation. View "Thomas v. Sumner" on Justia Law

At approximately 10:18 p.m., police officers searched Defendant’s home pursuant to a search warrant and found marijuana and drug paraphernalia. Defendant was subsequently arrested and charged with delivery of and possession with intent to deliver a controlled substance. Defendant filed a motion to suppress the evidence seized in the search, arguing that the search was unlawful and in violation of his constitutional rights because the search warrant was served after 10 p.m. contrary to the plain language of the warrant. The district court granted the motion to suppress based upon a procedural violation of Wyo. R. Crim. P. 41(c). The Supreme Court reversed, holding that although the officers violated Rule 41(c), the violation did not warrant suppression of the evidence seized in the search under the circumstances of this case. View "State v. Deen" on Justia Law

When Father and Mother were divorced, Mother was awarded primary custody of the parties’ son and Father was ordered to pay $400 per month in child support. The district court later entered an order finding Father’s monthly child support obligation to be $880 and ruled that he owed retroactive child support for twenty-seven months. Father appealed. The Supreme Court summarily affirmed, holding that because Father did not bring the Court a record sufficient to permit review of the issues he raised, the district court’s orders and rulings were assumed to be correct. View "Knezovich v. Knezovich" on Justia Law

Mother and Father were divorced in 2010. Mother was granted primary physical and legal custody of the children, and Father was given standard visitation. In 2013, Father filed a petition to modify custody, alleging that Mother was providing an unstable environment for the parties’ youngest daughter, GK. In his petition, Father sought primary custody of GK. The district court granted the petition, concluding that there had been a material change in circumstances affecting the child’s welfare sufficient to warrant modification regarding child custody. A divided Supreme Court reversed, holding that the district court abused its discretion in determining that the changes in Mother’s life created a material change in circumstances warranting the reopening of the existing custody order. View "Kappen v. Kappen" on Justia Law

After a jury trial, Appellant was convicted of one count of attempted second-degree sexual abuse of a minor. The Supreme Court affirmed, holding (1) the district court did not err by not declaring a mistrial after one potential juror made an improper remark and others who were ultimately excused became emotional during voir dire; (2) the district court did not abuse its discretion by supplementing the jury instructions consistent with the Information to clarify the conduct charged; and (3) the delay between Appellant’s conviction and sentencing did not violate his constitutional right to speedy sentencing. View "Brown v. State" on Justia Law

David Hartmann was injured during the course of his employment. After receiving surgery for his injury, Hartmann began experiencing dizzy spells. The Wyoming Workers’ Safety Compensation Division denied payment for the treatment Hartmann received for the dizziness. The Office of Administrative Hearings (OAH) found that Hartmann failed to prove a causal link between his dizzy spells and his work injury. The district court reversed, concluding that the OAH failed to apply the second compensable injury rule. The Division appealed. The Supreme Court affirmed the district court’s order to the extent it held the OAH failed to apply the second compensable injury rule but reversed the order remanding the case to the OAH for reconsideration, holding (1) the district court’s ruling was not an appealable order, but it is in the interest of judicial economy to treat the notice of appeal as a petition for review; (2) the OAH failed to invoke and apply the applicable law; and (3) when the applicable law is applied, the OAH decision to reject Hartmann’s evidence is against the overwhelming weight of the evidence. View "State, ex rel., Dep’t of Workforce Servs. v. Hartmann" on Justia Law

Appellants, property owners in Ryan Park and members of the Ryan Park Property and Homeowners Association, commenced an action claiming that the Association had unlawfully denied their requests to inspect and copy certain Association records. Appellants moved for an order allowing them to inspect and copy the documents, and also sought costs and attorney’s fees. The district court ordered the Association to make the documents available for copying and inspection but declined to order the Association to pay attorney’s fees or costs. On appeal, Appellants contended that the denial of attorney’s fees and costs was contrary to the provisions of the Wyoming Nonprofit Corporation Act. The Supreme Court affirmed, holding that the district court did not err in finding that the Association had made reasonable efforts to satisfy Appellants’ requests and in finding that the Association did not act in bad faith. View "Clark v. Ryan Park Prop. & Homeowners Ass’n" on Justia Law

Defendant pleaded guilty to a third or subsequent offense of possession of a controlled substance, a felony, and misdemeanor driving while under the influence. The Supreme Court affirmed, holding that the district court did not err by ordering Defendant to receive and pay for a substance abuse assessment and then by relying on the assessment at sentencing to determine that defendant was a “qualified offender” and, in turn, recommending that Defendant successfully complete substance abuse treatment while in prison through the Intensive Treatment Unit or a comparable program, as the district court’s decision was in accordance with the law. View "Marshall v. State" on Justia Law