Justia Wyoming Supreme Court Opinion Summaries

Mountain Regional Services, Inc. (MRSI), which provides services to individuals who receive medical benefits administered by the Wyoming Department of Health, filed a petition seeking judicial review of a “Provider Bulletin” issued by the Department concerning these benefits. The district court dismissed the petition for lack of ripeness and because MRSI failed to exhaust its administrative remedies before seeking judicial review. The Supreme Court affirmed, holding (1) the district court correctly concluded that the matter was not ripe for judicial review, and (2) therefore, it was unnecessary to consider the issue of exhaustion of administrative remedies.View "Mountain Reg’l Servs., Inc. v. State ex rel., Dep’t of Health" on Justia Law

After a jury trial, Defendant was found guilty of first degree sexual assault for forcing a young woman to perform oral sex on him. Defendant appealed, arguing that his trial counsel rendered ineffective assistance in three respects. The Supreme Court affirmed Defendant’s conviction and sentence, holding that Defendant did not prove that his counsel was constitutionally ineffective for (1) seeking to introduce evidence under Wyoming’s rape shield statute; (2) failing to investigate Defendant’s “probable level of intoxication” before an interview with law enforcement; and (3) failing to object to a statement made by the prosecutor during her rebuttal closing argument. View "McGarvey v. State" on Justia Law

Father and Mother were the parents of AD, born in 2009. In 2011, Father filed a complaint for child custody seeking primary physical custody of AD. After a trial, the district court awarded Father primary physical custody of AD, granted Mother liberal visitation with AD, and ordered Mother to pay $289 per month in child support. The Supreme Court affirmed, holding (1) there was no abuse of discretion in the visitation schedule ordered by the district court; (2) the district court did not abuse its discretion in its order on child support; and (3) the district court’s limitation of Father’s cross-examination did not result in any deprivation of Father’s right to due process.View "Davidson v. Carrillo" on Justia Law

Plaintiff-corporation brought a breach of contract action against Defendant-corporation. Defendant counterclaimed for breach of contract and breach of the covenant of good faith and fair dealing. A jury found that Plaintiff had breached the contract but awarded Defendant no damages. Plaintiff appealed. The Supreme Court affirmed, holding (1) the district court did not err in giving a breach of contract instruction or a challenged verdict form to the jury; and (2) the district court correctly exercised its discretion when its excluded Plaintiff’s expert testimony and reports and evidence involving a separate transaction between the parties.View "Black Diamond Energy, Inc. v. Encana Oil and Gas (USA) Inc." on Justia Law

In April 2011, Appellant was arrested for driving under the influence of alcohol (DUI) and pleaded guilty to DUI. The Wyoming Department of Transportation (WYDOT) did not notify Appellant until August 2012 that he would be disqualified from using his commercial driver’s license for one year and that his driver’s license would be suspended for ninety days. The Office of Administrative Hearings (OAH) upheld the suspension and disqualification. Appellant filed a petition for judicial review, challenging the proceedings instituted nearly a year and a half after his DUI conviction. The district court affirmed the OAH decisions. The Supreme Court affirmed, holding (1) the administrative proceedings were promptly instituted as required by Wyo. Stat. Ann. 16-3-113; and (2) Appellant did not establish that the delay deprived him of procedural due process. View "Dubbelde v. State ex. rel. Dep’t of Transp." on Justia Law

The Jackson Hole Hereford Ranch was divided by a series of conveyances between entities controlled by a brother (“Brother”) and sister (“Sister”), who disagreed on the validity of language purporting to reserve or convey an easement from Sister’s property across Brother’s property. Brother filed a complaint to quiet title and for injunctive relief, asserting that the requirements for finding an express or implied easement had not been met. Sister counterclaimed, asserting that a valid easement existed. The district court granted summary judgment in favor of Brother, concluding (1) the parties failed sufficiently to describe the easement, and therefore, the express easement was void; and (2) because the parties specifically contemplated an easement but failed to effectuate their intent, implying an easement would be inappropriate. The Supreme Court reversed, holding that that an express easement existed across Brother’s property. View "Leeks Canyon Ranch, LLC v. Callahan River Ranch, LLC" on Justia Law

In 2004, Appellant fell while working and strained her back. Appellant was awarded worker’s compensation benefits. In 2009, Appellant slipped and fell at work and injured her ankle. In 2010, Appellant sought temporary total disability and medical pay benefits from the Workers Compensation Division, which denied Appellant’s requests. After a contested case hearing, the Office of Administrative Hearings (OAH) upheld the Division’s denial of Appellant’s request for benefits, concluding Appellant did not meet her burden of proving that she suffered aggravation of a preexisting back condition as a result of a work related injury or that she suffered a second compensable injury. The district court affirmed. The Supreme Court affirmed, holding that the OAH did not err by failing to find a causal connection between the 2009 workplace incident and Appellant’s delayed back pain. View "Hirsch v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

After a jury trial, Defendant was found guilty of three counts of second-degree sexual assault. The Supreme Court affirmed, holding (1) Defendant was not denied his right to a speedy trial; (2) the district court properly admitted forensic interview evidence as a prior consistent statement; (3) the bill of particulars was sufficient for Defendant to adequately prepare a defense; (4) the circuit court committed harmless error when it granted an ex parte motion quashing Defendant’s subpoena to call the victim and her mother as witnesses at a preliminary hearing; (5) the district court did not abuse its discretion when it denied admission of sexualized behavior evidence on relevancy and hearsay grounds; and (6) the State did not commit prosecutorial misconduct when it referenced a non-religious quote from a church sign in its opening statement.View "Ortiz v. State" on Justia Law

Defendant pled guilty to felony larceny and was placed on probation subject to placement in an adult community correctional facility. Shortly after that placement, Defendant checked out of the facility and did not return. Defendant subsequently pled guilty to felony escape from official detention. The district court revoked Defendant’s probation and sentenced Defendant on both the larceny and escape convictions. A year and a half later, Defendant filed a combined Wyo. R. Crim. P. 35 motion for sentence reduction and motion for injunction seeking an order enjoining the Wyoming Board of Parole from interpreting Wyoming law in a manner that would preclude him from parole eligibility. The district court concluded that it lacked authority to rule on the motion because Defendant filed it outside the one-year period allowed for sentence reduction motions. The Supreme Court dismissed Defendant’s appeal, holding that the district court was without subject matter jurisdiction to consider Defendant’s motion on the basis that the motion was filed outside the time limits prescribed by Rule 35(b), and consequently, the Court was without jurisdiction to consider this appeal. View "Hitz v. State" on Justia Law

Appellant pled guilty to charges of strangulation of a household member, domestic battery, and reckless endangerment. The district court sentenced Appellant to three to five years on the strangulation charge to be served concurrent with a one year sentence on the domestic battery charge. Appellant subsequently filed a motion for sentence reduction based on his good behavior while incarcerated. The district court denied the motion. The Supreme Court affirmed, holding that, given the circumstances of this case and the Court’s longstanding precedent regarding sentence reduction motions based on a defendant’s behavior while incarcerated, the district court did not abuse its discretion in denying Appellant’s motion to reduce his sentence.View "Gilmer v. State" on Justia Law