Justia Wyoming Supreme Court Opinion Summaries

Defendant, a resident alien who was living in the United States legally, pled guilty to the charge of strangulation of a household member. Before Defendant was sentenced, he learned that his guilty plea would result in his deportation. Defendant subsequently moved to withdraw the plea, arguing that his counsel’s performance was deficient. The district court determined that Defendant had succeeded in demonstrating that his counsel’s performance was deficient, but nonetheless denied Defendant’s request to withdraw his plea, concluding that Defendant failed to prove that he was prejudiced by his counsel’s failure to advise him of the possibility of deportation. The Supreme Court reversed, holding that, because of the exceptional circumstances of Defendant’s counsel’s failure to advise Defendant of his assured deportation, Defendant’s counsel provided ineffective assistance, and, therefore, there was a fair and just reason to allow Defendant to withdraw his guilty plea. View "Ortega-Araiza v. State" on Justia Law

Margaret Reynolds and Jean Moore were involved in a car accident in which Margaret was injured. Jean was employed by Judith and Wilford Jaeger at the time of the accident. Margaret and her husband (the Reynolds) filed a complaint against Moore and the Jaegers, alleging negligence claims against Moore and respondeat superior claims against the Jaegers. The district court dismissed the Reynolds’ complaint, concluding (1) Moore was not sufficiently served for the court to obtain jurisdiction; and (2) Plaintiffs’ claims against the Jaegers were derivative of the claims asserted against Moore and could not be maintained in Moore’s absence. The Supreme Court reversed, holding (1) the district court erred by dismissing the Reynolds’ action against Moore, as Moore was properly served; and (2) because Moore’s dismissal was improper, the claim against the Jaegers should not have been dismissed. Remanded.View "Reynolds v. Jaeger " on Justia Law

After a trial, Defendant was convicted of six counts of sexual abuse of a minor in the third degree and one count of sexual abuse of a minor in the second degree. During trial, Defendant called a witness who opined about Defendant’s good character when interacting with children. On cross-examination, the trial court allowed the prosecutor to ask the witness if she knew Defendant had two prior convictions for sexually assaulting children. The Supreme Court affirmed, holding that the district court did not abuse its discretion in concluding that Defendant opened the door to character evidence under Wyo. R. Evid. 404(a)(1) and Wyo. R. Evid. 405(a), and the State’s presentation of rebuttal character evidence did not violate Defendant’s constitutional right to present a defense.View "McDowell v. State" on Justia Law

Stowe was driving on a dry highway with her seven-year-old daughter when their vehicle ran off the road. It travelled 318 feet and rolled twice before stopping. A passerby contacted law enforcement and emergency medical services. A trooper was told that Stowe slurred her words and gave off the overpowering odor of an alcoholic beverage. When Stowe first explained the cause of the accident, she told stated that she had swerved to avoid hitting a deer. She later stated that she had swerved to avoid a rabbit. Believing that there was probable cause to arrest Stowe for driving while intoxicated, but needing to locate and examine the crash scene, a trooper asked to have a deputy in Casper go to the hospital and obtain a blood or urine sample. Stowe had been catheterized due to the possibility of back injuries, so a nurse drew urine samples using a port built into the catheter. Tests indicated a .17% alcohol concentration. Stowe entered a conditional nolo contendere plea to a felony charge of fourth-offense driving while under the influence of alcohol. The Wyoming Supreme Court rejected arguments that the results of the test should have been suppressed because her urine was collected pursuant to an unlawful arrest because the officer lacked probable cause to believe that she had been driving while intoxicated and that the result of her urinalysis was invalid because it was collected from a catheter in a manner contrary to methods approved by the State Department of Health.View "Stowe v. State of Wyoming" on Justia Law

Andrea Richard allegedly violated the Wyoming Rules of Professional Conduct in seven different court proceedings between 2006 and 2012 by failing to comply with discovery requests and orders, causing her clients to be subjected to sanctions and expenses. According to the court she has substantial experience in the practice of law, she acted dishonestly or with a selfish motive, there was a pattern of misconduct, there were multiple offenses, she acted in bad faith to obstruct the disciplinary process by intentionally failing to comply with the rules, she refused until the very end of the process to acknowledge the wrongfulness of her conduct and the victims were vulnerable. The court adopted the recommendation of the Board of Professional Responsibility and suspended Richard from the practice of law for three years, among other sanctions. View "Bd. of Prof'l Responsibility, WY State Bar v. Richard" on Justia Law

After Appellants purchased vacant property in Laramie they discovered that an apartment building on an adjacent property encroached five feet onto their property. Appellants brought an action against the owners of the apartment building (Appellees) seeking a declaration that they owned the encroaching portion of the apartment building, an order requiring that the building be partitioned and that Appellees be ejected from the building, and an apportionment of rental income earned from the apartment building. Appellees counterclaimed, seeking a declaration that they had an implied easement over portions of Appellants’ parcel occupied by the apartment building and requesting an injunction to enjoin Appellants from interfering with the implied easement. The district court (1) concluded Appellants had no ownership interest in the apartment building and denied the remainder of Appellants’ requests; and (2) ruled that Appellees were entitled to an implied easement on Appellants’ property to accommodate the apartment building and enjoined Appellants from interfering with Appellees’ use of that easement. The Supreme Court affirmed, holding that the district court did not err in ruling that (1) Appellants had no ownership interest in the apartment building; and (2) Appellees held an implied easement on Appellants’ property. View "Miner v. Jesse & Grace, LLC" on Justia Law

At issue in this case was a joint operating agreement (JOA) for Wyoming oil and gas interests entered into in 2000 by the predecessors in interest to Windsor Energy Group, LLC and Windsor Beaver Creek, LLC (together, Windsor) and Noble Energy, Inc. (Noble). In 2004, Noble’s predecessor assigned its interest to another party. In 2010, Windsor filed suit against Noble’s predecessor, claiming it was obligated for costs under the JOA. The district court ruled (1) an assignor of an interest who was not formally released was still obligated under the JOA, but (2) Windsor’s claim against Noble for breach of the JOA was barred by laches. The Supreme Court affirmed the district court’s judgment without addressing the contract issue, holding that the district court (1) did not err in ruling that the equitable doctrine of laches was an available defense to Windsor’s claim for breach of the JOA even though the statute of limitations had not expired; and (2) did not abuse its discretion by finding the elements of laches were satisfied in this case. View "Windsor Energy Group, LLC v. Noble Energy, Inc." on Justia Law

Defendant was charged with making a false statement to obtain welfare benefits. Pursuant to a plea agreement, Defendant pled guilty to amended charge of misdemeanor interference with a peace officer and agreed to pay restitution in an amount to be determined after Defendant’s codefendant went through her plea or trial. Nearly two years after Defendant’s plea and sentencing, the district court issued a ruling requiring Defendant to pay restitution in the amount of $2,600. The Supreme Court reversed and vacated the restitution order, holding that the order was not supported by sufficient evidence, as the State presented no evidence that Defendant received or otherwise benefited from a welfare fraud scheme in the amount of $2,600. View "O'Halloran v. State" on Justia Law

The Wyoming Department of Transportation notified Appellant that his commercial driver’s license would be disqualified for one year on the basis that Appellant had driven a commercial vehicle with a blood alcohol concentration of 0.04 percent or greater. Appellant requested a contested case hearing. A hearing examiner upheld the Department’s decision. The district court affirmed the license disqualification. On appeal, Appellant contended that the hearing examiner’s findings of fact were unsupported by substantial evidence. The Supreme Court affirmed, holding (1) substantial evidence supported the hearing examiner’s decision; and (2) any errors regarding the hearing examiner’s findings of fact were harmless.View "McCallie v. State ex rel. Dep’t of Transp." on Justia Law

In 2008, Plaintiff and Defendant were involved in an automobile accident. In 2012, Plaintiff filed a complaint against Defendant alleging that Defendant’s negligent motor vehicle operation caused the collision, resulting in serious injury to Plaintiff. Defendant filed a motion to dismiss, alleging that Plaintiff’s action was barred by the statute of limitations. The district court agreed and granted Defendant’s motion to dismiss with prejudice. Plaintiff appealed, arguing that the district court’s consideration of evidence outside the pleadings converted Defendant’s motion to a summary judgment motion and that genuine issues of material fact precluded dismissal. The Supreme Court affirmed, holding (1) Defendant’s motion was converted to a summary judgment motion, but no issues of material fact precluded entry of the court’s order, and (2) the court properly denied Plaintiff’s assertion of equitable estoppel and correctly ruled that Plaintiff’s action was barred by the statute of limitations. View "Inman v. Boykin" on Justia Law