Justia Wyoming Supreme Court Opinion Summaries

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

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

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

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