Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of one count of first degree murder and sentenced to life imprisonment. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in deciding to overrule Defendant’s objection to the court’s admission of certain testimony, as the evidence was not, as Defendant alleged, uncharged misconduct in violation of Wyo. R. Evid. 404(b); (2) the prosecutor did not commit misconduct during closing argument; and (3) the district court did not err in failing to instruct the jury in accordance with the Court’s decision in Eagan v. State.View "Gonzalez-Ochoa v. State" on Justia Law

After a jury trial, Appellant was convicted of felony driving while under the influence of alcohol. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in denying in part a pretrial discovery request made by Appellant; (2) the district court did not violate Appellant’s constitutional right to confrontation when the State’s expert witness testified as to the operation, maintenance, and accuracy of the breath alcohol test machine used in this case; and (3) Appellant’s trial counsel was not ineffective in not calling an expert witness to testify as to the effect of diabetes on the results of a breath alcohol test.View "Anderson v. State" on Justia Law

Evelyn Carlsen, a settlor of the 1999 Carlsen Family Living Trust who also served as trustee, amended the trust on two separate occasions before she died. After Mrs. Carlsen’s death, Appellant Catherine Meyer, a beneficiary of the trust who stood to receive less because of the amendments, brought an action against Appellee, the successor trustee, challenging the validity of the amendments. The district court granted summary judgment in favor of Appellee. The Supreme Court affirmed, holding that the district court (1) did not err in concluding that the amendments were valid because their terms did not constitute a repayment of a debt, which might invoke the Statute of Frauds; and (2) properly determined that there were no genuine issues of material fact with regard to Appellant’s claim that Mrs. Carlsen was unduly influenced to amend the trust by other beneficiaries. View "Meyer v. Miller " on Justia Law

After a jury trial, Appellant was convicted for possession, delivery, and conspiracy to deliver methamphetamine. On appeal, Defendant challenged the admission of photographic evidence of items in his home containing methamphetamine, arguing that the evidence constituted evidence of uncharged misconduct under Wyo. R. Evid. 404(b) because it suggested that Appellant was manufacturing methamphetamine. The State responded that the evidence was substantive evidence of the crimes charged and was thus not uncharged misconduct evidence. The Supreme Court affirmed the convictions, holding that the district court did not abuse its discretion in admitting the challenged evidence because it was intrinsic to the crimes charged and was not uncharged misconduct evidence. View "Hernandez v. State" on Justia Law

Defendant entered Alford pleas to promoting prostitution, conspiracy to commit first degree sexual assault, and aggravated assault and battery on a pregnant woman. The victim in this case was Defendant’s girlfriend. The district court imposed suspended sentences of incarceration and ten years probation to run consecutively with a term of imprisonment for the conspiracy charge. One of the conditions of Defendant’s probation was that Defendant have no contact with the victim of the offense or the minor children of the victim and Defendant. Defendant appealed, arguing that the “no contact” condition of his probation was not reasonably related to his rehabilitation and was an encroachment upon his fundamental right to raise his children. The Supreme Court affirmed, holding that the district court did not abuse its discretion in imposing the “no contact” condition of probation in Defendant’s sentencing. View "Perkins v. State" on Justia Law

Appellant, acting as the personal representative for her deceased mother’s estate, sued Star Valley Medical and Care Centers and several of their employees (collectively, Appellees), alleging that Appellees’ negligence caused her mother’s death. Before filing her complaint, Appellant submitted a governmental claim as required by the Wyoming Governmental Claims Act (WGCA). Appellees filed a motion for summary judgment alleging that Appellant’s claim was defective because it was not signed under oath or penalty of perjury as required by the current WGCA and the Wyoming Constitutions. The district court found that, for these reasons, the claim was invalid and granted summary judgment to Appellees. The Supreme Court reversed, holding (1) the claim requirements set forth in the WGCA and Wyoming Constitution are nonjurisdictional substantive requirements that can be waived; and (2) although the claim in this case did not meet statutory and constitutional requirements, Appellees failed to adequately raise the claim’s deficiencies as an affirmative defense and therefore waived that defense. View "Harmon v. Star Valley Med. Ctr." on Justia Law

After an investigation, police learned that Defendant, a band teacher, had sexual relations with three students at Rock Springs High School. The State charged Defendant with a total of fifteen counts of sexual abuse of a minor. Pursuant to a plea deal, Defendant pleaded guilty to three counts, and the State dismissed the remaining charges. At the sentencing hearing, several students, including two of the victims, testified on Defendant’s behalf. The district court sentenced Defendant to a fifteen to twenty-five-year sentence for one count of sexual abuse of a minor in the first degree, to be served concurrently with the sentences imposed on the other counts. The Supreme Court affirmed, holding that the district court (1) properly exercised its discretion in sentencing Defendant and in considering statements made by the victims as aggravating rather than mitigating; and (2) did not violate Defendant’s due process rights when it recessed his sentencing hearing and continued it to the next day. View "Thompson v. State" on Justia Law

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