Justia Wyoming Supreme Court Opinion Summaries

Forsberg Engerman Co., an insurance agency, helped Lewis Holding Co., a trucking business, purchase insurance from Lexington Insurance Co. In 2011, one of Lewis Holding’s trailers was damaged. After Lewis Holding filed an insurance claim, NTA, Inc.’s adjuster examined the trailer and determined that the damage was due to mechanical failure or wear and tear. Lexington denied the insurance claim on the grounds that the damages were not the result of an upset or collision, but rather, the result of improper welding. Lewis Holding subsequently filed suit against Lexington, NTA, and Forsberg. The district court granted summary judgment for Defendants. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment for Defendants where (1) the insurance agreement plainly and unambiguously excluded coverage for damages due to mechanical failure; (2) Forsberg, who was not a party to the insurance contract, could not be held liable under the insurance policy; and (3) Defendants had reasonable bases for denying Lewis Holding’s claim.View "Lewis Holding Co., Inc. v. Forsberg Engerman Co." on Justia Law

In 1999, Appellant experienced a workplace injury to her back, for which she received benefits awarded by the Wyoming Workers’ Safety and Compensation Division (“Division”). In 2008, while employed in Nebraska, Appellant suffered a second workplace injury. Appellant filed a worker’s compensation claim in Nebraska relating to her 2008 injury and subsequently settled that claim. In 2010, Appellant sought payment for prescription medication for headaches she was experiencing, claiming that the treatment was related to her 1999 injury. The Division denied benefits, concluding that the treatment and medications were unrelated to the original compensable 1999 injury. After a contested case hearing, the Office of Administrative Hearings upheld the Division’s denial of benefits. The district court affirmed. The Supreme Court affirmed, holding that substantial evidence supported the hearing examiner’s finding that there was no causal connection between Appellant’s headaches and her 1999 workplace injury. View "Landwehr v. State ex rel. Workers’ Safety & Comp. Div. " on Justia Law

Dan C. Morton successfully bid on several federal oil and gas leases. Morton sought the assistance of RDG Oil and Gas, LLC to develop the leases. In 2005, the parties entered into two separate agreements for the development of the leases. In 2012, Morton’s successor in interest, the Jayne Morton Living Trust, filed a complaint against RDG alleging breach of contract of both agreements. RDG did not respond to the complaint, and the district court entered a default judgment against RDG. RDG later moved to set aside the entry of default and the default judgment. The district court denied RDG’s motions. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying RDG’s motion to set aside the entry of default and the entry of default judgment. View "RDG Oil & Gas, LLC v. Jayne Morton Living Trust " on Justia Law

The Andrews, a married couple, contracted to purchase a newly constructed home from Appellants, Joe Seneshale and his company, Legacy Builders, LLC (together, Legacy). After the Andrews took possession of the property, they discovered that the house had numerous structural and cosmetic flaws. The Andrews filed a complaint against Legacy alleging breach of contract and breach of implied warranty of habitability. The trial court entered judgment in favor of the Andrews and awarded a total of $319,302 in damages. The Supreme Court affirmed but remanded with instructions to correct the damage award, holding (1) when the cost of repairs in a homeowners’ construction case alleging breach of contract and breach of warranty may be disproportionate to the loss in value to the home resulting from the breach, the plaintiff has the burden of proving damages at trial, and the defendant has the burden of challenging the reasonableness or disproportionality of the plaintiff’s method; and (2) the district court did not commit clear error when it relied upon the majority of the Andrews’ cost of repair expert’s testimony and when it found that expansive soils caused damages to the home’s foundation. View "Legacy Builders, LLC v. Andrews" on Justia Law

Father filed for divorce from Mother in 2011. After a trial, the trial court entered a divorce decree granting Mother physical custody of the children and awarding visitation to Father, ordering Father to pay child support, dividing the marital property, and awarding alimony to Mother. The Supreme Court affirmed the trial court’s decision in all respects, holding that the trial court did not abuse its discretion in (1) the division of property between the parties; (2) awarding alimony to Mother; (3) its calculation of child support; and (4) determining the custody and visitation of the children.View "Stevens v. Stevens" on Justia Law

A defendant was charged with sexual assault of a minor in connection with an AMBER Alert and a missing child. The deputy county attorney requested that the circuit court restrict disclosure of information of the case in accordance with Wyo. Stat. Ann. 6-2-319(a). The circuit court granted the request and sealed the court file and barred news organizations (Appellees) from attending any court proceedings. Appellees moved to intervene to gain access to information pertaining to the case, but the defendant was bound over to the district court before the circuit court ruled on the motion. Appellees filed a declaratory judgment action in the district court seeking a ruling on whether section 6-2-319(a) required the closure of records and proceedings in cases alleging sexual assault. The district court granted summary judgment for Appellees. The Supreme Court affirmed, holding that the circuit court (1) violated the First Amendment when it closed the court proceedings and sealed the court records; and (2) incorrectly interpreted section 6-2-319(a) when it determined that the statute required the court to seal the criminal case file and close all proceedings held in its courtroom without a hearing or findings on the record. View "Circuit Court v. Lee Newspapers" on Justia Law

In this adverse possession case, Henry and Simona Prado purchased a lot in 1966 and used a strip of land under the mistaken belief that the land was theirs. In 1989, Tracy and Norma Lampman brought the lot to the east of the Prados that included the narrow parcel. The owners of each lot each apparently believed they owned the strip of land. In 2011, Christopher and Tami Graybill entered into a contract for deed with the Prados, took possession of their lot, and began using the disputed strip of land. When a survey established the true property line, the Lampmans fenced off the disputed parcel. The district court quieted title in the Lampmans, concluding that the Graybills and the Prados (collectively, Appellants) did not own the disputed area by adverse possession. The Supreme Court reversed, holding that Appellants established their adverse possession claim by a preponderance of the evidence, and the district court erred in finding to the contrary. Remanded. View "Graybill v. Lampman" on Justia Law

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