Justia Wyoming Supreme Court Opinion Summaries

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

In 2005, Tara Kobielusz began working for Circle C Resources, which provides living assistance for persons with developmental disabilities. In 2010, Kobielusz began working for Circle C as a “host family provider.” That same year, Kobielusz fell and broke her ankle when entering Circle C’s office to pick up Kobielusz’s clients from their day habilitation program. The Workers’ Safety and Compensation Division found Kobielusz had suffered a compensable injury. Circle C requested a contested case hearing before the Office of Administrative Hearings (OAH), arguing that Kobielusz was not an employee, but rather, an independent contractor. The OAH upheld the Division’s determination. The district court affirmed. The Supreme Court affirmed, holding that Kobielusz did not qualify as an “independent contractor” under the meaning of the Worker’s Compensation Act.View "In re Worker’s Comp. Claim of Kobielusz" on Justia Law

After a jury trial, Defendant was found guilty of larceny, wrongful disposal of stolen property, and burglary arising from the theft and sale of two saddles to a pawn shop. Defendant appealed, arguing that the district court abused its discretion when it admitted other bad acts evidence that Defendant pawned another saddle that allegedly belonged to her sister. The Supreme Court affirmed, holding that because the other bad acts evidence was not admitted for any proper purpose, the district court abused its discretion by allowing it into evidence, but, under the circumstances of this case, the error was harmless. View "Payseno v. State" on Justia Law

Appellant pled guilty to the federal charge of being a felon in possession of firearms. Thereafter, Appellant pled guilty at the state level to aiding and abetting burglary. The federal court sentenced Appellant to a term of imprisonment, and the state district court sentenced Appellant to a term of imprisonment to run concurrently with the federal sentence. Thereafter, Appellant filed an appeal, which he voluntarily dismissed, and two successive motions for sentence reduction, which the state district court denied and Appellant did not appeal. Appellant subsequently filed a motion to correct and illegal sentence, which the district court denied. This appeal concerned Appellant’s second motion to correct an illegal sentence. The district court denied the motion, concluding that the doctrine of res judicata applied to bar Appellant’s claim. The Supreme Court affirmed, holding that res judicata barred review of Appellant’s claim because he did not take advantage of the opportunity to raise it multiple times before. View "Dax v. State" on Justia Law