Justia Wyoming Supreme Court Opinion Summaries

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

After conducting a compliance examination of CalCon Mutual Mortgage Corporation (“CalCon”) the Wyoming Department of Audit, Division of Banking (“Division”) determined that CalCon had violated the Wyoming Residential Mortgage Practices Act in six separate brokering transactions by receiving application fees and “yield spread premiums” exceeding those previously disclosed to its customers. The Division requested that CalCon refund the application fees and yield spread premiums to the borrowers. CalCon objected and requested a contesting case hearing before the Office of Administrative Hearings (“OAH”). The OAH determined that CalCon had violated the Act. The State Banking Commissioner subsequently issued a final order directing CalCon to reimburse the fees. The district court affirmed. The Supreme Court affirmed, holding that the Commissioner properly interpreted Wyo. Stat. Ann. 40-23-114 in determining that CalCon was required to provide a written explanation of increased application fees and yield spread premiums in the transactions at issue. View "Calcon Mut. Mortgage Corp. v. State ex rel. Wyo. Dep’t of Audit, Div. of Banking" on Justia Law

Defendant entered into a conditional plea agreement pursuant to which he pled guilty to interference with a peace officer and reserved the right to appeal three issues. The district court affirmed the circuit court’s rulings on those three issues. The Supreme Court reversed after addressing only one issue that was not addressed by either party, holding (1) because one of the three issues included in Defendant’s conditional plea was not a valid pretrial motion and was therefore not reviewable in a conditional plea appeal, the entire plea was invalid; and (2) therefore, Defendant should be allowed to withdraw his conditional guilty plea. Remanded.View "Matthews v. State" on Justia Law

After a jury trial, Appellant, an inmate at the Wyoming State Penitentiary, was convicted of two counts of conspiracy to deliver a controlled substance and two counts of conspiracy to take a controlled substance into a state penal institution. The Supreme affirmed the convictions, holding (1) there was no violation of Defendant’s right to a speedy trial, where the time between Defendant’s arraignment and trial was 201 days, as the delay was part of the due administration of justice and thus did not violate Wyo. R. Crim. P. 48; and (2) the district court did not abuse its discretion when it denied Appellant’s motion to continue.View "Vargas v. State" on Justia Law