Justia Wyoming Supreme Court Opinion Summaries

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

Plaintiffs, individually and on behalf of their children, filed a complaint against Defendants, alleging injury resulting from their rental of a house containing black mold. Defendants made an offer of settlement pursuant to Wyo. R. Civ. P. 68, which Plaintiffs did not accept. Plaintiffs voluntarily dismissed certain claims, and the district court entered judgment as a matter of law for Defendants on the remaining claims. Thereafter, Defendants filed a certificate of costs through which they sought an award of costs pursuant to Wyo. R. Civ. P. 68 and 54(d) and Uniform Rules for District Courts (U.R.D.C.) 501. The district court awarded costs. Plaintiffs appealed, arguing, among other things, that the court erred in awarding costs pursuant to rule 68. The Supreme Court affirmed in part and reversed in part the district court’s award of costs, holding that Rule 68 did not apply to the award of costs in this matter, and that, instead, costs were governed by Rule 54(d). View "Graus v. Ok Invs., Inc." on Justia Law

Plaintiff-tenants filed a complaint against Defendant-landlords alleging injures from carbon monoxide poisoning caused by a gas stove on property Plaintiffs rented from Defendants. Defendants made an offer of settlement to Plaintiffs pursuant to Wyo. R. Civ. P. 68, which Plaintiffs did not accept. After a trial, the jury returned a verdict in favor of Defendants. Thereafter, Defendants filed a motion for costs in the amount of $45,410 pursuant to Wyo. R. Civ. P. 68 and 54(d) and the Uniform Rules for District Courts (U.R.D.C.) 501. The district court awarded Defendants costs in the amount of $1,326 after applying U.R.D.C. 501. The Supreme Court appealed, holding (1) an award of costs pursuant to Rule 68 is governed by Rule 501 and Wyo. Stat. Ann. 1-14-102; and (2) the district court did not abuse its discretion by denying the majority of the costs requested by Defendants pursuant to Rule 54(d) and U.R.D.C. 501. View "Weinstein v. Beach" on Justia Law

Mother and Father divorced in 2007, and Mother was awarded primary residential custody of the parties’ child subject to Father’s visitation. In 2013, Father filed a motion requesting that the district court enter judgment against Mother for unpaid day-care expenses incurred by Father. Mother responded by filing a motion to modify the divorce decree as it related to daycare expenses. The district court granted Father’s outstanding claims for child support abatement and eliminated Father’s right to claim child support abatement during periods in which Mother pays for daycare expenses. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in eliminating Father’s ability to claim child support abatement for periods in which Mother pays the costs of daycare; (2) the district court did not abuse its discretion in refusing to grant prejudgment interest to Father; and (3) Mother was entitled to costs and attorney’s fees incurred in this appeal. View "Jensen v. Milatzo-Jensen" on Justia Law

In 2011, Ted Price, as Trustee of the Price Family Trust, filed an application for the establishment of a private road asserting that his property had no outlet to or connection with a public road. The Crook County Board of Commissioners denied the application on the ground that Price already had access to his property from at least two existing public roads. The district court affirmed. The Supreme Court affirmed, holding (1) the Board’s decision denying Price’s private road application was supported by substantial evidence, the actions of the Board were not arbitrary or capricious, and the record did not establish the level of inconvenience required to establish necessity; and (2) the district court did not err in denying Price’s request that the final result be set aside due to malfunctioning audio equipment. View "Price v. Hutchinson" on Justia Law

In 2004, after Mother filed a complaint for divorce, Mother and Father entered into a property settlement and child custody agreement. Due to Mother’s problems with alcohol, Father was later granted primary residential custody of the parties’ children. In 2013, Mother filed a petition to modify child support on the basis of her unemployment. The district court denied child support modification, concluding that Mother was not entitled to modification because she was voluntarily unemployed. The Supreme Court affirmed, holding that the district court did not abuse its discretion in concluding that Mother was voluntarily unemployed. View "Levene v. Levene" on Justia Law

Petitioner was arrested for driving while under the influence of alcohol. Petitioner initially refused to take a breath test until the arresting highway patrol trooper said that a search warrant would be obtained and that a blood sample could be forcibly obtained if Petitioner did not cooperate. Petitioner then submitted to the breath test, which he failed. The trooper then issued Petitioner a notice of license suspension. After a contested case hearing, the Office of Administrative Hearings (OAH) upheld the proposed suspension. The district court reversed, concluding that Petitioner was tricked into submitting to the breath test by the trooper’s statements. The Supreme Court reversed, holding that the OAH correctly found that Petitioner was properly advised as required by statute and not tricked or misled. View "State ex rel. Wyo. Dep’t of Transp. v. Icenhower" on Justia Law

Philippe Lajaunie and Daren Singer were owners and co-managers of Beartooth Mountain Springs, LLC. Lajaunie sued Singer, claiming that Singer had breached his fiduciary duties as a manager and member of Beartooth. Singer counterclaimed based on a theory of promissory estoppel. The district court granted summary judgment for Lajaunie on Singer’s counterclaim and denied Singer’s motion to amend his counterclaim to allege a cause of action based on fraud. After a trial on Lajaunie’s claims, the jury awarded $14,604 in damages. The Supreme Court reversed, holding that the district court (1) erred in granting summary judgment on the promissory estoppel claim; (2) erred in denying Singer’s motion to amend the counterclaim; and (3) abused its discretion in admitting certain evidence at trial. View "Lajaunie v. Singer" on Justia Law

Pursuant to a plea agreement, Defendant pleaded no contest to second degree sexual abuse. Defendant was previously convicted of a similar offense and specifically acknowledged in the plea agreement that the sentence for a second conviction of second degree sexual abuse of a minor was life in prison without the possibility of parole. The district court sentenced Defendant to life in prison without the possibility of parole. The Supreme Court affirmed, holding (1) Defendant’s sentence of life without the possibility of parole did not violate the Eighth Amendment because it was not grossly disproportionate to the crime; and (2) the sentence did not violate Wyo. Const. art. I, 14. View "Norgaard v. State" on Justia Law