Justia Wyoming Supreme Court Opinion Summaries

Appellant was convicted of felony child abuse for physically abusing his fifteen-year-old daughter during a heated conversation about the daughter’s poor grades. The statute under which Appellant was convicted expressly provides that a defendant is not guilty of child abuse if the physical injury results from “reasonable corporal punishment.” Appellant argued that the jury instructions in this case were faulty because the district court failed properly to instruct the jury as to the elements of felony child abuse because the jury was not instructed that the State must prove beyond a reasonable doubt that the physical injury was not the result of discipline Appellant was permitted to administer. The Supreme Court reversed and remanded for a new trial, holding that district court failed properly to instruct the jury on the elements of felony child abuse, and the court’s error created confusion as to the burden of necessary elements of the crime and the burden of proof, resulting in prejudice to Appellant. View "Andersen v. State" on Justia Law

Jessica Hofhine filed for divorce from Mike Hofhine. The parties entered into a property settlement stipulation agreement that was incorporated into the decree of divorce entered by the district court. The next year, Jessica filed a “Motion for Enforcement of Judgment and Decree of Divorce,” claiming that she was entitled to an “income equalization” payment under the terms of the parties' divorce decree. The district court denied the motion on the basis that Jessica did not ask the court for compensation or equalization before the decree of divorce was entered. The Supreme Court affirmed, holding that the district court (1) did not err in its interpretation and application of the legal documents governing the property distribution between Jessica and Mike when it concluded that Jessica was not entitled to equalization of income under the parties’ divorce decree; (2) did not violate Jessica’s due process rights by refusing to permit any party or witness testimony at the hearing on Jessica’s motion; and (3) did not abuse its discretion in awarding attorney’s fees to Mike. View "Hofhine v. Hofhine" on Justia Law

Seventy-six-year-old William suffered from a lifelong mental disability. William’s brother Robert and sister Jeanne were the sole trustees of a trust established by William’s mother to support William. Because Williams had fallen prey to financial scammers, Robert and Jeanne took steps to prevent William from trust money. Thereafter, Robert petitioned for appointment as William’s guardian, and Jeanne cross-petitioned seeking to be appointed as William’s guardian and conservator. The district court dismissed Robert’s petition as a sanction for his failure to appear at a pretrial conference and temporarily appointed Jeanne as William’s guardian and conservator. The Supreme Court affirmed, holding (1) the district court properly dismissed Robert’s guardianship petition; (2) the district court did not abuse its discretion in disposing of Robert’s motions to submit the case to mediation and to quash the proposed order dismissing Robert’s petition; and (3) the district judge did not abuse his discretion in denying Robert’s petition to disqualify the presiding judge. View "In re Guardianship & Conservatorship of Bratton" on Justia Law

Plaintiff, as personal representative for Connie Scribner, filed a wrongful death complaint against Defendants, Dr. Sean Beyer and Emergency Medical Physicians, P.C., alleging that Defendants’ care of Scribner fell below the standard of care. The first trial ended in a mistrial, and a second trial was held. The jury rendered a verdict in favor of Defendants. Plaintiff appealed and Defendants cross-appealed. The Supreme Court affirmed, holding that the district court did not abuse its discretion in declaring a mistrial or in admitting the testimony of Dr. Beyer and Defendants’ emergency medicine expert concerning certain medical tests and a pneumonia severity index. View "Miller v. Beyer" on Justia Law

Pursuant to the Wyoming Public Records Act, Plaintiff requested from the Office of the Governor and the Wyoming Game & Fish Department (together, the State) documents related to the status of grizzly bears under the Endangered Species Act. The State provided some documents and withheld others on grounds of the deliberative process privilege and the attorney-client communication privilege. The district court held (1) the Act incorporates the deliberative process privilege as a ground to exempt documents from disclosure under the Act, and the documents withheld under the deliberative process privilege were properly withheld by the State; and (2) two of the three documents withheld under the attorney-client privilege were properly withheld. The Supreme Court (1) affirmed the district court’s ruling with respect to the documents withheld under the attorney-client privilege; (2) affirmed the district court’s ruling that the Act incorporates the deliberate process privilege; but (3) concluded that some of the documents withheld pursuant to the deliberative process privilege were not properly withheld because they were outside the scope of the privilege’s protection. View "Aland v. Mead" on Justia Law

Roger Seherr-Thoss (RST) owned and operated a gravel operation since at least 1977. In 1978, Teton County enacted its first Land and Development Regulations (LDRs). In 2011, Teton County issued RST an amended "notice to abate" requiring RST to reduce his production levels to pre-1978 levels because the business had expanded in volume and footprint since the LDRs were adopted. After a contested case hearing, the Teton County Board of County Commissioners entered an order recognizing that all aspects of RST’s gravel crushing and extraction operations were grandfathered but requiring RST to reduce its operation to its 1978 extent. The district court affirmed. The Supreme Court reversed, holding that the Board’s order was an improper agency determination and exercise of authority. View "Seherr-Thoss v. Teton County Bd. of County Comm’rs" on Justia Law

Gary Carl Stroth became very sick on September 23, 2010 and died a few days later. On October 11, 2012, Appellant submitted a notice of claim against the Star Valley Medical Center (Hospital), the Town of Thayne and the Thayne Ambulance Service, alleging the Hospital and Ambulance Service were negligent in their care of Stroth and that the Town was liable under the doctrine of respondeat superior. The district court dismissed the complaint, concluding that Appellant’s claim had not been timely filed under the Wyoming Governmental Claims Act (WGCA). The Supreme Court affirmed, holding that because Appellant presented her notice of claim more than two years after the accrual of her claim, the district court correctly dismissed her complaint for failure to submit a timely notice of claim under the WGCA. View "Stroth v. N. Lincoln County Hosp. Dist." on Justia Law

Defendant pleaded guilty to first-degree felony murder and aggravated burglary. Defendant was sentenced to life imprisonment on the murder charge. Defendant did not appeal his conviction. Instead, Defendant filed several motions and petitions concerning his conviction and sentence, to no avail. Here Defendant filed a number of motions challenging his sentence, claiming that it was illegal because in 2013 he was transferred from Wyoming to Virginia to serve out his sentence. The district court denied Defendant’s motions. The Supreme Court affirmed, holding that because Defendant challenged the way in which the State executed his sentences, rather than the legality of his sentences, his transfer to Virginia did not constitute an illegal sentence. View "Garnett v. State" on Justia Law

Frank Forelle and William Fix were neighbors in a subdivision. After Forelle built a fence on his property along the border of the parties’ adjoining properties, Fix complained that the fence violated the subdivision’s covenants. Fix, an attorney who represented himself in the matter, prevailed on his claim in the district court. Relying on a covenant provision regarding reimbursement for costs incurred in enforcing the covenants, Fix subsequently sought attorney fees. The district court awarded Fix attorney fees, but later, in an amended judgment, concluded that Fix could not recover fees for the legal work he performed because he did not actually incur any fees. The Supreme Court affirmed, holding that because Fix was never liable for or subject to his own attorney fees, he did not incur any fees, and therefore, Fix was not entitled to recover attorney fees for the work he performed in the litigation. View "Fix v. Forelle" on Justia Law

Defendant pleaded guilty to driving while under the influence of alcohol (DWUI). This was Defendant’s fourth such offense within the previous ten years, making it a felony under Wyo. Stat. Ann. 31-5-233(e) and subject to a sentence enhancement. Defendant filed a motion to strike two of four prior convictions, claiming that the two prior DWUI convictions were not constitutionally obtained and therefore should not have been relied upon for sentence enhancement purposes. The district court denied Defendant’s motion, ruling that because Defendant had not appealed from his earlier convictions the convictions could not be overturned. The court then enhanced Defendant’s conviction to a felony and sentenced Defendant accordingly. The Supreme Court affirmed Defendant’s enhanced sentence, holding that Defendant’s underlying convictions were constitutionally obtained. View "Derrera v. State" on Justia Law