Justia Wyoming Supreme Court Opinion Summaries

Appellant was placed on supervised probation. The district court also placed Appellant in an intensive supervision program (ISP). Appellant committed eleven violations of the rules while in the ISP, for which the ISP program gave Appellant an administrative sanction by placing him in a residential community corrections program. Due to Appellant’s violations of the rules while in the ISP, the State filed a petition for probation revocation. The district court revoked Appellant’s probation and imposed the underlying sentence. On appeal, Appellant argued that the ISP violations could not form the basis for a probation revocation because they had previously been subject to administrative sanctions. The Supreme Court reversed, holding that Appellant’s probation was revoked based on violations for which he had previously been punished with administration sanctions, in violation of Wyo. Stat. Ann. 7-13-1107. Remanded. View "Butler v. State" on Justia Law

In 2007, Appellant suffered a work-related injury to his right hip. In 2009, the Wyoming Workers’ Safety and Compensation Division denied Appellant’s requests for testing and treatment of pain in his back on the grounds that the requests were unrelated to Appellant’s work injury. The Office of Administrative Hearings (OAH) reversed and ordered that one additional test be performed to determine whether Appellant’s back problems were associated with his work injury. After the results of the test came back normal, the hearing examiner ordered that Appellant was not entitled to further benefits for his back. The district court affirmed. The Supreme Court affirmed as modified, holding (1) substantial evidence supported the OAH decision that Appellant did not satisfy his burden of proving additional testing and treatment of his back were related to his work injury; but (2) future treatment associated with the original hip injury could be submitted for administrative review.View "Delacastro v. State ex rel., Wyo. Workers' Safety & Comp. Div." on Justia Law

Defendant pleaded guilty to first-degree murder, aggravated burglary, and conspiracy to commit aggravated burglary. Defendant was sixteen years old when he committed the crimes. After imposing an initial sentence, the district court resentenced Defendant to life in prison with the possibility of parole after serving for twenty-five years on the felony murder charge, to run consecutive to the previously imposed sentence for aggravated burglary of twenty to twenty-five years, and concurrent to the sentence for conspiracy to commit aggravated burglary. The Supreme Court reversed and remanded to the district court with instructions to resentence on all counts, holding that sentencing courts are required to provide an individualized sentencing hearing to weigh the factors for determining a juvenile’s diminished culpability and greater prospects for reform when, as in this case, the aggregate sentences result the functional equivalent of life without parole. Remanded for resentencing. View "Bear Cloud v. State" on Justia Law

Appellant owned property as a tenant in common with Appellees, two relatives. Both parties sought to partition the property. The district court concluded that Appellant ousted Appellees from the property and, therefore, must pay them a fair rental value for the use of the property. Appellees became the successful bidders of the property at a second public sale, and the district court approved the sale. The Supreme Court affirmed, holding (1) the district court properly held that Appellant ousted the cotenant Appellees and must pay them the fair rental value for the time she exclusively occupied the property; (2) the district court’s calculation of the total amount of rent Appellant owed the cotenants was not clearly erroneous; (3) Appellees were entitled to bid at the public sale of the partitioned property and were entitled to bid the value of their interests in the property and a portion of the monetary award for rent in lieu of payment; and (4) Appellant was not entitled to a homestead exemption even though she occupied the partitioned property at times. View "Martin v. Prieto" on Justia Law

Pursuant to a plea agreement, Defendant pled no contest to one count of interference with a police officer. The State stood by its original plea agreement at the sentencing hearing and recommended a three to five year sentence which would be suspended and Defendant would be placed on probation. The district court did not follow this recommendation and instead sentenced Defendant to incarceration of three to six years. Defendant appealed, arguing that the district court abused its discretion in sentencing. The Supreme Court affirmed, holding that the district court did not abuse its discretion in sentencing Defendant after considering Defendant’s criminal history and the safety of the community. View "Croy v. State" on Justia Law

Plaintiff filed a complaint against four defendants alleging that they conspired to fabricate a mental incompetency determination in connection with criminal proceedings filed against Plaintiff in Utah. The district court dismissed Plaintiff’s case for failing to properly serve the defendants within ninety days of filing the complaint. The Supreme Court reversed, holding (1) questions existed whether the affidavits of service on three of the defendants established a prima case of valid service, and the fourth defendant waived any objection to lack of proper service; (2) the district court did not err in failing to enter a default against the defendants; and (3) the district judge did not err in not granting Plaintiff’s motion to transfer the case to another district court. Remanded for a hearing to determine the validity of service of process. View "Lundahl v. Gregg" on Justia Law

Appellant received worker’s compensation benefits in 1996 and 2004 for work-related injuries to his back. In 2008 and 2011, Appellant underwent surgeries to treat a herniated disc in his low back. The Wyoming Workers’ Compensation Division denied Appellant’s application for benefits to cover the two surgeries and any other expenses incurred after 2005. On appeal, Appellant contended that the herniated disc was a direct result of his 1996 and 2004 injuries and was therefore a second compensable injury. The Office of Administrative Hearings (OAH) upheld the Division’s denial of benefits. The district court affirmed. The Supreme Court affirmed, holding that the OAH’s decision upholding the denial of benefits was supported by substantial evidence and not contrary to the overwhelming weight of the evidence.View "Bodily v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

After a jury trial, Defendant was found guilty of one count of felony child abuse. The Supreme Court affirmed, holding that the district court (1) did not violate Defendant’s right to confrontation by allegedly limiting the cross-examination of the victim regarding inappropriate sexual contact between the victim and his sister because the district court did not make a ruling on the issue; and (2) did not abuse its discretion by not granting Defendant’s motion for judgment of acquittal because there was sufficient evidence such that a jury could return a guilty verdict.View "Swan v. State" on Justia Law

After a jury trial, Appellant was convicted of aggravated assault by threatening to use a drawn deadly weapon. On appeal, Appellant argued, among other things, that his trial counsel provided ineffective assistance for failing to call an expert witness. The Supreme Court reversed and remanded for a new trial, holding (1) there was sufficient evidence to support the jury’s verdict; (2) Appellant did not receive constitutionally effective counsel, and, under the circumstances, a reasonable probability existed that, but for trial counsel’s deficient performance, the outcome would have been different; and (3) the jury was improperly instructed on self defense.View "Cooper v. State" on Justia Law

Recently-adopted regulations required companies engaged in hydraulic fracturing to disclose the chemical compounds used in the process to the Wyoming Oil and Gas Conservation Commission. Appellants sought from the Commission disclosure of certain chemicals used in several companies’ hydraulic fracturing products. The Commission Supervisor refused to disclose the information, concluding that it was exempt from public disclosure as trade secrets under the Wyoming Public Records Act (WPRA). Appellants sought review of the Supervisor’s decision. The district court affirmed. The Supreme Court reversed and remanded, holding (1) the district court did not have the authority to evaluate the Supervisor’s decision using an administrative standard of review, and rather, should have used the procedures specified in the WPRA; and (2) the definition of a trade secret under the WPRA is the one articulated by federal courts under the Freedom of Information Act. View "Powder River Basin Res. Council v. Wyo. Oil & Gas Conservation Comm’n" on Justia Law