Justia Wyoming Supreme Court Opinion Summaries

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

Defendant pled guilty to one count of solicitation to commit property destruction. On appeal, Defendant argued (1) the district court lacked subject matter jurisdiction because he was in West Virginia at the time of the alleged solicitation, and (2) he received ineffective assistance of counsel. The Supreme Court affirmed, holding (1) the State had subject matter jurisdiction to prosecute Appellant for charges specified in the charging Information, as Defendant intended his criminal actions to have an effect in Wyoming; and (2) Appellant failed to carry his burden of showing that his representation by trial counsel was so ineffective that it rendered Appellant’s guilty plea involuntary. View "Turner v. State" on Justia Law

Defendant entered a conditional Alford plea to possession of a controlled substance. On appeal, Defendant challenged the district court’s denial of her motion to suppress evidence, arguing that she should have been permitted to leave the scene of a traffic stop when she asked to leave, that the arresting officer lacked reasonable suspicion to detain her, and that she should have been read her Miranda rights. The Supreme Court affirmed, holding (1) law enforcement had reasonable, articulable suspicion on which to detain Defendant; and (2) under the circumstances of this case, Defendant was not entitled to receive Miranda rights. View "Engdahl v. State" on Justia Law

After a jury trial in Sweetwater County, Appellant was found guilty of third-degree sexual abuse of a minor for offenses committed against a fifteen-year-old girl on a Greyhound bus. Defendant filed a motion for judgment of acquittal, arguing that the State had not offered evidence to prove that the crime had occurred in Sweetwater County. The Supreme Court affirmed, holding (1) that prosecutor’s tactics did not amount to judge-shopping so as to deprive Appellant of his constitutional right to due process; (2) the jury was correctly instructed regarding venue; (3) the evidence established that venue in Sweetwater County was proper; and (4) the prosecutor’s misstatement of the law regarding venue in her closing argument did not constitute reversible error. View "Anderson v. State Employment Sec. Div." on Justia Law