Justia Wyoming Supreme Court Opinion Summaries

Appellant first received benefits for work-related injuries he received to his knees in 1992. In 2009, Appellant requested preauthorization to perform total knee replacement on both knees. The Workers’ Safety and Compensation Division denied the request and also denied payment of continued treatment of Appellant’s knees, concluding that the treatment and total knee replacements were not associated with the 1992 work injury. After a contested case hearing, the Medical Commission upheld the Division’s decision. The Supreme Court affirmed, holding (1) the Medical Commission did not commit prejudicial error during the hearing by admitting into evidence, over Appellant’s objection, three exhibits; and (2) substantial evidence supported the Commission’s decision.View "Johnson v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

In 1997, the Courtenay C. Davis Foundation and Amy Davis (together, “Davis Interests”) entered into an agreement with the University of Wyoming Foundation and the Colorado State University Research Foundation (together, “University Foundations”) in which the Davis Interests donated land and other interests to the University Foundations subject to the terms of the agreement. In 2011, the University Foundations decided to sell the gifted property and listed it for sale. In 2012, the Davis Interests filed an action against the University Foundations seeking to enjoin the sale of the property. The district court dismissed the complaint for lack of standing. The Supreme Court affirmed, holding that the district court did not err in concluding that the donation from the Davis Interests to the University Foundations was a gift, that the agreement did not create an implied trust, and that only the attorney general had standing to enforce the terms of a charitable gift.View "Courtenay C. & Lucy Patten Davis Found. v. Colo. State Univ. Research Found." on Justia Law

Appellant was originally injured in 1975 while working for his employer. Appellant’s injuries resulted in the amputation of his right leg, below the knee. The Wyoming Workers’ Safety and Compensation Division paid a number of benefits over the years. Years later, Appellant began receiving chiropractic treatment, including cold laser therapy, from Utah Spine and Disc Clinic in Murray Utah. Appellant sought reimbursement for travel to and from the clinic. In 2011, the Division denied Appellant’s request for reimbursement because (1) traditional types of chiropractic care, manipulation, and traction could have been obtained at a location in Wyoming closer to Appellant’s home; and (2) cold laser therapy was considered experimental and was therefore not a covered treatment for which the Division would pay travel expenses. The Supreme Court affirmed, holding that the Division did not err in its interpretation of the applicable Wyoming statutes, and the Division’s decision contained adequate findings of fact, which findings were supported by substantial record evidence.View "Birch v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Appellant pled guilty to burglary and attempted assault on a peace officer and nolo contendre to four counts of interference with custody. The district court sentenced Appellant to prison on each of the counts but suspended the sentence in favor of supervised probation consisting of two terms: a ten-year term followed by a two-year term. The district court later found that Appellant had violated the terms of his probation, revoked probation, imposed the underlying consecutive sentences, and credited Appellant for time served. The Supreme Court affirmed the probation revocation. Thereafter, Appellant filed a pro se motion to correct illegal sentence, arguing that the first term of his probation was revoked after he had already completed it. The Supreme Court affirmed, holding (1) the doctrine of res judicata applied to bar the issue raised in Appellant’s current appeal; and (2) the district court’s revocation of Appellant’s probation was timely. View "DeMillard v. State" on Justia Law

Montana-Dakota Utilities Company (MDU) was ordered by the Wyoming Public Service Commission to make refunds of the amounts MDU had overcharged its customers because of improper calculations and adjustments to its commodity balancing account. MDU filed a petition for review, challenging the legal authority of the Commission to order refunds. The district court affirmed the Commission’s decision. The Supreme Court affirmed, holding (1) the rule against retroactive ratemaking did not preclude the Commission from ordering the refund; (2) the Commission’s refund order did not violate the file rate doctrine; (3) the Commission was not subject to a statute of limitations in this case; (4) MDU failed to show that the Commission was equitably estopped from ordering a refund; and (5) the Commission’s action was not arbitrary, capricious, an abuse of discretion, or unlawful. View "Montana-Dakota Utils., Co. v. Wyo. Pub. Serv. Comm’n" on Justia Law

Appellant was convicted after a jury trial of aggravated battery stemming from an altercation with his girlfriend and his girlfriend’s sister. The Supreme Court affirmed, holding (1) there was sufficient evidence to establish that the victim suffered serious bodily injury, and therefore, the jury could have determined beyond a reasonable doubt that Appellant was guilty of the crime for which he was convicted; (2) the district court did not commit plain error when it instructed the jury on the theory of self-defense; and (3) the prosecutor’s statements throughout trial were clearly improper, but Appellant was not materially prejudiced as a result of the prosecutor’s misconduct. View "Brown v. State" on Justia Law

In 2011, Decedent died of injuries incurred in an automobile accident. Decedent was survived by his allegedly estranged wife, Laura Soran, and by his parents and sister. Decedent’s father, in his capacity as personal representative, brought a wrongful death claim brought against Robert Curran, the driver of the vehicle in which Decedent was a passenger when he died, and settled with Curran’s insurance providers for $400,000. A dispute subsequently arose between Decedent’s beneficiaries as to how the settlement proceeds should be distributed. The district court awarded Laura seventy-five percent of the settlement proceeds and divided the remainder among Decedent’s parents and sister. The Supreme Court reversed, holding that the district court’s distribution order was clearly erroneous in that it misapplied the burden of proof and improperly presumed damages in favor of Decedent’s wife where Decedent’s marital relationship was uncertain. Remanded.View "In re Wrongful Death of Daniel P. Soran" on Justia Law

After H. Kent Dahlke died in 2003, leaving a will he had executed in 2001, there were irregularities in the administration of Kent’s estate, including the probate court’s failure to advise Kent’s surviving wife, Sara Dahlke, of her statutory elective share, and the court’s failure to assure that Kent’s heirs waived a hearing on a decree of distribution. Sara later died. In 2011, five years after the decree of distribution of Kent’s estate was entered and its assets were distributed to the devisees, Sara’s daughter, Susan Jubie, acting as the personal representative of Kent’s estate, the personal representative of Sara’s estate, and individually, sought to set aside the decree of distribution of Kent’s estate. The district court declined to set the decree aside. The Supreme Court affirmed, holding that although the probate process went awry in this case, the law governing finality of judgments required that the decree of dissolution stand.View "Estate of Dahlke" on Justia Law

Appellant pleaded guilty to two counts of attempted voluntary manslaughter pursuant to a plea agreement and was sentenced to two consecutive terms of incarceration of seventeen to twenty years. The Supreme Court affirmed the convictions and sentences, holding (1) the district court did not err in accepting Appellant’s guilty pleas in exchange for the plea agreement, as the plea agreement and the guilty pleas were valid; and (2) the district court did not err in sentencing Appellant in accordance with the terms of the plea agreement and in the range provided by statute.View "Noel v. State" on Justia Law

In 2004, Appellant pled guilty to three counts of felony identity theft. The district court imposed a sentence of incarceration that it suspended in favor of eight years probation. In 2008 and 2009, the State filed three petitions to revoke Appellant’s probation, and each time, the district court revoked and reinstated probation. In 2011, the State filed a fourth petition to revoke. The district court granted the petition and imposed the underlying sentence of five to nine years incarceration. Appellant did not timely appeal from the district court’s order revoking probation and imposing sentence. However, after the district court found that counsel was ineffective in failing to follow Appellant’s instruction to file an appeal, the Supreme Court restored the appeal from the probation revocation. The Supreme Court subsequently affirmed the district court’s order revoking probation, holding that the evidence supported the district court’s decision to revoke Appellant’s probation, and the decision was not an abuse of discretion. View "Allaback v. State" on Justia Law