Justia Wyoming Supreme Court Opinion Summaries
Dean v. State
After a jury trial, Defendant was found guilty of felony stalking for stalking his estranged wife in violation of a protection order. The district court sentenced Defendant to a term of incarceration of nine to ten years. The Supreme Court affirmed the conviction and sentence, holding (1) the State presented sufficient evidence to prove beyond a reasonable doubt that Defendant acted with the requisite intent to harass his victim; and (2) the district court did not commit reversible error when it instructed the jury concerning the elements of the crime of stalking. View "Dean v. State" on Justia Law
Posted in:
Criminal Law
Campbell v. State
Appellant was charged with four drug-related felonies. Appellant filed a motion and an amended motion to suppress the evidence police officers obtained against him in a search of Appellant’s apartment. The district court denied the motion, and Appellant entered a conditional guilty plea to felony possession of marijuana. Appellant appealed, challenging the denial of his motion to suppress. The Supreme Court reversed, holding that the district court (1) erred in concluding that the initial intrusion into Appellant’s apartment was lawful and justified by the emergency assistance exception to the Fourth Amendment’s warrant requirement; and (2) correctly found that Appellant’s consent to the police’s later entry into and search of his apartment was voluntarily given. Remanded for a ruling on whether Appellant’s consent was tainted by the initial unlawful search of his apartment. View "Campbell v. State" on Justia Law
Silva v. State
Appellant was convicted of aggravated burglary and attempted kidnapping. The district court sentenced Appellant to twelve to fifteen years imprisonment on each conviction, the two sentences to run concurrently. The Supreme Court affirmed the convictions and sentences on appeal. Appellant subsequently filed a motion to reduce his sentence. The district court denied the motion. The Supreme Court affirmed without addressing the merits of Appellant’s claims, as Appellant’s brief in many respects failed to comply with the requirements of Wyo. R. App. P. 7.01 and Appellant's arguments were either improperly raised on appeal or not cogent. View "Silva v. State" on Justia Law
Posted in:
Criminal Law
LP v. LF
The case centered around Appellant’s claim that he was the actual and presumptive father of a ten-year-old child. The district court granted the Mother’s petition to establish that Appellant was not the child’s father. The Supreme Court affirmed, holding that the district court did not err in (1) granting Mother’s petition to prove that Appellant was not the child’s biological father under the Wyoming Parentage Act; and (2) not finding that Appellant was a de facto parent or a parent by estoppel because the Court declined to adopt de facto parentage or parentage by estoppel, leaving instead that policy decision to the Wyoming Legislature. View "LP v. LF" on Justia Law
Posted in:
Family Law
In re Worker’s Compensation Claim of Stevens
In October 2010, Appellant slipped and fell down a flight of stairs outside of her workplace. In January 2011, Appellant was diagnosed with avascular necrosis (AVN) in the femoral head of her right hip. Eventually, the femoral head on her right hip collapsed due to the AVN progression, and in December 2011 Appellant received a total right hip replacement. The Wyoming Department of Workforce Services, Workers’ Safety and Compensation Division denied Appellant’s claim for medical treatment of the AVN, concluding that Appellant’s October 2010 fall did not cause her to then develop AVN. After a contested case hearing, the Office of Administrative Hearings (OAH) agreed and denied benefits. The Supreme Court affirmed, holding that the OAH’s findings of fact and conclusions of law were supported by substantial evidence and were in accordance with the law. View "In re Worker's Compensation Claim of Stevens" on Justia Law
Counts v. State
In 2011, after a jury trial, Defendant was convicted of aggravated burglary and kidnapping and found to be a habitual criminal. The district court sentenced Defendant to two concurrent life sentences. The Supreme Court affirmed the convictions and sentences. In 2013, Defendant filed a motion to correct an illegal sentence, arguing that one of the convictions the district court relied upon for the habitual criminal determination and the life sentences occurred when he was only sixteen years old and that consideration of that offense to impose a life sentence was unconstitutional under Miller v. Alabama. The district court denied Defendant’s motion to correct an illegal sentence. The Supreme Court affirmed, holding that the sentencing scheme at issue here did not mandate a life sentence for a juvenile, and therefore, Miller did not apply. View "Counts v. State" on Justia Law
Sen v. State
Appellant, a juvenile, was convicted and sentenced. The Supreme Court reversed Appellant’s sentence, instructing that, if a sentence of life according to law was imposed, the district court must specify a period of parole ineligibility. The district court did as instructed and imposed a sentence of life according to law with the specification that Appellant was eligible for parole on the sentence after thirty-five years. The Supreme Court vacated the sentence imposed by the district court, holding that Appellant should be resentenced because the district court did not consider the analysis from Miller v. Alabama “in light of the entire sentencing package.” View "Sen v. State" on Justia Law
Posted in:
Juvenile Law
Boutelle v. Boutelle
Sister filed a negligence action against Brother for injuries she sustained in a single-vehicle accident that occurred in Montana. Brother moved for summary judgment, contending that because the accident occurred in Montana, Wyoming’s borrowing statute required application of Montana’s three-year statute of limitations, and therefore, Sister’s action was barred. The Supreme Court affirmed, holding that the district court did not err in (1) rejecting application of Montana’s choice-of-law statutes in applying Wyoming’s borrowing statute; (2) determining that Sister’s cause of action arose in Montana; and (3) applying Montana’s three-year statute of limitations to bar Sister’s cause of action. View "Boutelle v. Boutelle" on Justia Law
Posted in:
Injury Law
Kordus v. Montes
Twelve-year-old J.K. underwent an appendectomy performed by Appellee, but complications arose requiring additional surgery and medical treatment. Appellants, on behalf of J.K., filed a medical malpractice claim against Appellee. Appellee moved to dismiss, alleging that the claim was barred by the two-year statute of limitations contained in Wyo. Stat. Ann. 1-3-107(a)(ii). The district court granted the motion. Appellants appealed, arguing that the statute, as applied to minors, violates the Wyoming Constitution. The Supreme Court agreed and therefore reversed, holding that section 1-3-107(a)(ii) violates the open courts provision of Wyoming’s Constitution by restricting a minor’s access to the courts. Remanded. View "Kordus v. Montes" on Justia Law
Posted in:
Constitutional Law, Medical Malpractice
DeLauter v. Seneca Ins. Co., Inc.
Jeffrey Irene was injured after being struck by a vehicle driven by Douglas Downs. Downs had been arrested for driving while under the influence of alcohol two hours before the incident, but Eric Overlie, a licensed bail bondsman and an agent of Lederman bonding company, posted bail to procure Downs’ release from custody. Seneca Insurance Company guaranteed the bond. Irene and the conservator of Irene’s minor children filed a negligence action against Overlie, Lederman, and Seneca. The district court granted Defendants’ motions to dismiss, concluding that the suit had not been filed within the two-year statute of limitations that governs causes of action arising from the rendering of licensed or professional services. The Supreme Court reversed, holding that the facts in the complaint did not establish that Overlie was rendering licensed or professional services when he released Downs from his custody. View "DeLauter v. Seneca Ins. Co., Inc." on Justia Law
Posted in:
Injury Law