Justia Wyoming Supreme Court Opinion Summaries

After a jury trial in 1982, Defendant was found guilty of aggravated robbery and unauthorized use of a vehicle. The Supreme Court affirmed Defendant’s convictions on appeal. Before Defendant began serving his Wyoming sentence, he was released to federal authorities to serve a sentence on unrelated federal charges. In 1988, Defendant was returned to Wyoming to begin serving his Wyoming sentence. In 2013, Defendant filed a petition to correct sentence, arguing, among other things, that his sentence was illegal because he was not given credit for time served in the federal facility and because the sentence was disproportionate to the severity of his crime. The district court denied the motion. The Supreme Court affirmed, holding that Defendant’s claims were barred by the doctrine of res judicata because Defendant had multiple opportunities to assert his current sentencing claims and prosecute appeals related to those claims, and he offered no acceptable justification for his failure to do so. View "Gee v. State" on Justia Law

A school district (District) notified Plaintiff, a continuing contract teacher in the District, that his contract would be terminated on grounds of incompetence, insubordination, and poor work performance. Following a hearing, an independent hearing officer concluded that good cause existed for the termination of Plaintiff’s teaching contract and recommended that the contract be terminated for insubordination. The school district board of trustees (Board) accepted the hearing officer’s recommendation and conclusion. Plaintiff appealed, arguing that the Board’s order was entered in violation of the Wyoming Administrative Procedure Act (APA) and his due process rights because some members of the Board did not attend the entire hearing or otherwise review all of the evidence submitted to the hearing officer. The Supreme Court affirmed, holding that the Board did not err by accepting the hearing officer’s recommended decision without independently reviewing the entire evidentiary record received by the hearing officer. View "Wadsworth v. Bd. of Trs. of Lincoln County Sch. Dist. No. Two" on Justia Law

Defendant, a contractor, and Plaintiff, a subcontractor, entered into a two subcontracts for part of a road work project. Plaintiff invoiced Defendant for the work under both contracts, but when Defendant failed to pay the full amount, Plaintiff filed suit for breach of contract damages and storage fees for Defendant’s equipment and materials. Defendant counterclaimed, alleging that Plaintiff had been overpaid on the contracts and had converted Defendant’s equipment. Defendant moved to have the matter removed to federal court and filed its counterclaim in that court. The case was subsequently remanded to state court, where Defendant filed its counterclaim. Plaintiff moved for summary judgment, claiming Defendant’s counterclaim was untimely. The district court granted the motion and dismissed the counterclaim. After a bench trial, judgment was entered in favor of Plaintiff. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate any basis to reverse the district court’s dismissal of its counterclaim on summary judgment; (2) alternatively, Defendant’s proposed counterclaim was moot; and (3) Plaintiff was entitled to attorney fees and costs. View "Motzko Co. USA, LLC v. A & D Oilfield Dozers, Inc." on Justia Law

Appellants decided to sell 850 acres of farmland but wanted to retain the mineral rights. Summit Title Services prepared the deeds for the sale, but he deeds did not reserve the minerals. Appellants were made aware of the omission at closing, insisted that the deeds be corrected, and were assured by Summit’s employee that the problem had been rectified. Six years later, Appellants learned that the minerals had been transferred with the land. Appellants filed suit against Summit, its general counsel Olen Snider, and Kuzma Success Realty, a brokerage firm involved in the transaction. The district court granted summary judgment for Appellees on all claims, concluding that Appellants failed to exercise due diligence to discover the error so as to extend the statute of limitation as a matter of law. The Supreme Court reversed the grant of summary judgment to Summit and Snider, concluding that there were genuine issues of material fact as to whether Appellants exercised due diligence to discover errors allegedly made by Summit and that Snider failed to present a prima facie case that he was entitled to summary judgment. View "Moats v. Prof'l Assistance, LLC " on Justia Law

In 2001, Appellant moved into Decedent’s home at Decedent’s request, where he lived and cared for Decedent until Decedent’s death in 2010. After Decedent’s death, Appellant filed a creditor’s claim against Decedent’s estate, seeking compensation for the care and services he provided. Defendants, the co-administrators of the estate, denied Appellant’s claim. Appellant subsequently brought an action against Defendants. The district court granted summary judgment to the estate. The Supreme Court affirmed, holding that the district court did not err in finding no question of material fact existed and that Appellant failed as a matter of law on his claims for implied-in-fact contract, promissory estoppel, and unjust enrichment. View "Symons v. Heaton" on Justia Law

Plaintiffs filed a medical malpractice action against the Campbell County Memorial Hospital under the Wyoming Governmental Claims Act (Act), alleging that Amanda Phillips, a certified nurse anesthetist for Northern Plains Anesthesia Associates, which provided anesthesia services for the hospital, acted as an employee or agent of the hospital, making the hospital vicariously liable for Phillips’ alleged negligence. The hospital filed a motion for partial summary judgment, arguing that a government hospital could not be vicariously liable for acts of non-employees or independent contractors under the doctrine of ostensible agency. The district court denied the motion based on Sharsmith v. Hill. The Supreme Court reversed, holding that the district court erred in its interpretation of Sharsmith and that Sharsmith did not create an implied waiver of sovereign immunity under the Act. View "Campbell County Memorial Hosp. v. Pfeifle" on Justia Law

Mother and Father were divorced pursuant to a decree that awarded the parties joint custody of their two children with each parent allowed to have the children fifty percent of the time. Mother later sought to modify the decree. The district court modified the custody, visitation, and child support provisions of the decree, awarding each parent primary custody of one child and ordering Father to reimburse Mother for certain medical costs and other expenses. Father appealed, contending that the district court abused its discretion by declining to determine the amount Father owed Mother to reimburse her for medical expenses. The Supreme Court affirmed, holding (1) the district court properly declined to determine what amount, if any, Father owed Mother for medical expenses; and (2) therefore, the district court did not abuse its discretion in declining to enter an order for a specific amount. View "Carbaugh v. Nichols" on Justia Law

Defendant entered conditional pleas of guilty to possession of a controlled substance with intent to deliver and conspiracy to deliver a controlled substance. Defendant appealed the district court’s denial of her motion to suppress, arguing that marijuana evidence discovered in her vehicle following a traffic stop was the product of an unlawful detention. Specifically, Defendant argued that her detention was unreasonable because the questioning of Defendant was not tailored to the traffic stop and was not supported by a reasonable suspicion that a crime was being committed. The Supreme Court affirmed, holding that, under the totality of the circumstances, the questioning and detention of Defendant were reasonable and did not violate Wyo. Const. art. I, 4. View "Klomliam v. State" on Justia Law

Appellant was charged and convicted of felony driving while under the influence of alcohol, reckless driving, driving with a suspended license, and driving without an interlock device. On appeal, Appellant argued (1) his constitutional right to a speedy trial was violated because he spent 332 days incarcerated after he was arrested and before his trial began, and (2) the State failed to present sufficient evidence to support the reckless driving conviction. The Supreme Court affirmed, holding (1) although the delay between Appellant’s arrest and trial was approximately eleven months, Appellant’s right to a speedy trial was not violated; and (2) the State presented sufficient evidence to support Appellant’s conviction for reckless driving. View "Mascarenas v. State" on Justia Law

When Mother and Father divorced, Mother was awarded primary custody of the parties’ child. Father later field a petition for modification of custody and time-sharing. The district court found there had been a substantial change of circumstances and that it was in the child’s best interest for Father to be awarded custody. Mother appealed, claiming (1) the district court did not have jurisdiction over Father’s petition for modification of custody due to Father’s failure to comply with the statutory pleading requirements; (2) her due process right was violated when default was improperly entered against her; and (3) the district court abused its discretion in entering a child support order due to its failure to comply with statutory child support requirements. The Supreme Court affirmed, holding (1) the district court had subject matter jurisdiction over Father’s petition; (2) Mother was given the process she was due; and (3) the district court correctly ruled on the child support issue. View "Brush v. Davis" on Justia Law