Justia Wyoming Supreme Court Opinion Summaries

Landowners Merlin and Lori Zowada filed a petition with the Board of County Commissioners to establish a private road to access their landlocked tract of property through property owned by Mullinax Concrete Service Company. The Board considered six alternative routes for the private road. After the Board ruled on the petition, the Supreme Court determined that the case should be remanded to the commissioners to compare the relative merits of only two alternative routes, Route 1 and Route 6, and to determine whether the greater cost of Route 6 was justified. After further proceedings, the Board established the road along Route 6. The Zowadas sought review of that decision. The Supreme Court affirmed the Board’s findings of fact and conclusion of law, holding that the Board’s decision to establish the private road along Route 6 was supported by substantial evidence. View "Zowada v. Mullinax Concrete Serv. Co., Inc." on Justia Law

Enrique Herrera was working for Gilligan’s LLC under the supervision of Robert Phillipps when he was injured. Herrera was an alien who was not authorized to work in the United States at the time of the injury. Herrera filed a lawsuit against Gilligan’s and Phillips, alleging that Defendants were negligent and that, if that Worker’s Compensation Act applied, Phillipps’ conduct was intentional and he was therefore liable as a co-employee. The district court granted summary judgment for Gilligan’s and Phillipps, concluding primarily that there was no genuine dispute as to the material fact that Defendants reasonably believed Herrera was authorized to work in the United States, and therefore, Defendants were immune from suit pursuant to the Act. The Supreme Court reversed, holding that there was sufficient evidence to raise a genuine issue of material fact as to whether Gilligan’s had a reasonable belief that Herrera was authorized to work in the United States and whether Phillipps acted in intentional disregard of a dangerous condition when he instructed Herrera to perform his work. Remanded. View "Herrera v. Phillipps" on Justia Law

Robert Carson and his passenger, Hugh Sharp, were involved in a car accident in which Carson sustained multiple injuries and Sharp was killed. Carson filed a claim for worker’s compensation benefits. The Wyoming Workers’ Safety and Compensation Division denied benefits, finding that Carson’s injuries did not arise out of and in the course of his employment with Metrocities Mortgage, LLC. The Office of Administrative Hearings (OAH) upheld the denial of Carson’s claim. Meanwhile, Sharp’s widow filed a wrongful death action against Carson and Metrocities. After a trial, a federal jury entered judgment against Metrocities under the theory of respondeat superior, concluding that Carson was acting within the course of scope of his employment when the accident occurred. On the basis of the federal judgment, Carson submitted a motion to reopen his claim with the OAH, contending that there was newly discovered evidence he was acting within the course of his employment at the time of the accident. The OAH eventually affirmed its earlier decision. The Supreme Court affirmed, holding that the OAH did not err when it failed to apply collateral estoppel to the issue of whether Carson was in the course and scope of his employment at the time of his injury.View "Carson v. State ex rel., Wyo. Workers' Safety & Comp. Div." on Justia Law

This third appeal concerned a judgment obtained by David and Elizabeth Speaks against Byron Baker. Two properties, the Corsi Ranchettes lot and the Misty Meadows lot, were fraudulently transferred by Byron and Rosemary Baker to their son, Nathan, who, in turn, transferred the properties to Bryner Farms, LLC, a family-owned company, which conveyed the properties to Pat’s Dream Project Trust and MME Trust (collectively, “the Baker Defendants”). The Baker Defendants asserted the property was exempt from execution from the judgment against Byron, alone, because it was held by Byron and Rosemary as tenants by the entirety. The district court concluded (1) the Bakers were not married when they took title to the Corsi Ranchettes property, and therefore, Byron’s interest was not entitled to protection from legal process; and (2) the Speaks brought the action to declare the Misty Meadows property transaction fraudulent within the applicable limitations period. The Supreme Court affirmed, holding (1) the district court properly found that the Speaks were entitled to execute on Byron’s interest in the Misty Meadows lot; and (2) the district court did not err in concluding that the Bakers could not create a valid tenancy by the entirety with regard to the Corsi Ranchettes lot. View "Baker v. Speaks" on Justia Law

The Star Valley Ranch Association mounted an effort to amend the restrictive covenants governing the Star Valley Ranch subdivision. Appellees, owners of property in the subdivision, challenged the validity of the amended covenants by filing suit in the district court. Specifically, Appellees sought a declaration that the amendments were invalid because the Association had not complied with the previous covenants’ requirements for amendments. Appellees also sought an injunction prohibiting the Association from implementing and enforcing the amended covenants. The district court granted summary judgment for Appellees. The Supreme Court affirmed, holding (1) the district court did not err in holding that the amended covenants were invalid; (2) the Association’s claim of impracticability failed; and (3) Appellees had standing to challenge the amendments as a single, unified set of covenants applicable to the entire subdivision. View "Star Valley Ranch Ass’n v. Daley" on Justia Law

In 2013, Bryan Skoric, the Park County Attorney, reconsidered the extent of his office’s participation in civil commitment proceedings and decided not to continue to participate in emergency detention hearings under Wyo. Stat. Ann. 25-10-109 or to appear and prosecute the case in chief at involuntary hospitalization hearings under Wyo. Stat. Ann. 25-10-110. Appellants, the West Park Hospital District and Yellowstone Behavioral Health Center, filed a petition for writ of mandamus asking the district court to compel Skoric to proceed in the same way as he had in the past. The district court denied Appellants’ application for the writ. The Supreme Court affirmed, holding (1) the statutes in question do require a county attorney’s office to participate in civil commitment proceedings; but (2) the statutes are ambiguous, and therefore, extraordinary relief was not warranted when Appellants filed their petition. View "State ex rel. West Park Hosp. Dist. v. Skoric" on Justia Law

After the Wyoming Department of Family Services (DFS) learned that JM, a minor, had several unexcused absences from school, a deputy count attorney filed a petition alleging that JM was a neglected child because Mother had failed to provide adequate education for JM’s well being. Following a hearing, the juvenile court entered an order of neglect. Mother appealed, claiming that the juvenile court was without jurisdiction to adjudicate the petition because the district court was required to give her notice and counseling before the petition was filed, and she did not receive such notice or counseling. The Supreme Court affirmed, holding that the compulsory attendance statutes upon which Mother relied, which require school districts to give parents notice or counseling based on students’ unexcused absences, do not apply when a juvenile petition is filed by a prosecuting attorney under the Child Protection Act on the basis of a complaint from DFS alleging neglect. View "In re JM" on Justia Law

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