Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of larceny by bailee. Defendant appealed, arguing (1) the district court erred in excluding alternate suspect evidence and in giving an improper jury instruction, and (2) the evidence was insufficient to support the conviction. The Supreme Court reversed the conviction and remanded with instructions to enter a judgment of acquittal, holding that the evidence presented at trial was not sufficient under Wyoming law to support the guilty verdict, given Defendant’s the lack of any evidence of motive, ill will, any attempt to avoid apprehension by law enforcement, or physical evidence linking Defendant with the stolen property. View "Mraz v. State" on Justia Law

After a jury trial, Appellant was convicted on two separate charges of delivery of a controlled substance and one charge of possession of a controlled substance. After the Supreme Court affirmed on appeal, Appellant filed a motion to correct an illegal sentence, asserting that his two convictions and sentences on two charges of delivery resulted in his being punished twice for the same offense in violation of the prohibition against double jeopardy. The district court denied the motion. The Supreme Court affirmed, holding that because Defendant committed two separate and distinct crimes on two separate dates, each charge included an element that was unique, and thus, double jeopardy did not attach. View "Mebane v. State" on Justia Law

Robert and Beverly Bernard sought a special exemption to operate a bed and breakfast in an area that was zoned as an R-1 Residence District. The Board of Adjustments approved the Bernards’ application, but the district court reversed because the agency failed to comply with its own rules and procedures. The Bernards subsequently filed a second application for a special exemption that differed from the first in that it included an approved parking plan and a certificate of occupancy. Timothy and Carole Tarver objected, claiming that the Bernards’ second application was barred by res judicata. The Board concluded that the second application was not barred by res judicata and granted the Bernards’ application with conditions. The Tarvers appealed. The Supreme Court affirmed, holding (1) the Bernards’ second application for a special exemption was not barred by res judicata or collateral estoppel; (2) the Board had the authority to impose parking restrictions on the bed and breakfast as a condition of granting the special exemption; and (3) the Board properly applied its discretion in concluding that the Bernards were entitled to a special exemption. View "Tarver v. Bd. of Adjustments" on Justia Law

After Peggy Gheen died, her sons discovered quitclaim deeds Mrs. Gheen had executed to them for her interests in a residential property and a farm. The Gheen sons subsequently recorded the deeds. The State ex rel. Dep’t of Health, Div. of Healthcare Financing/Equitycare (Department) filed a lien against both properties to recover the cost of Medicaid benefits paid on behalf of Mrs. Gheen before her death. The Gheen sons filed a petition to remove a false lien and quiet title, claiming they were the rightful owners of the property. The Department moved for summary judgment, asserting that it had a valid lien because Mrs. Gheen owned the properties at the time of her death and the quitclaim deeds were not valid. The district court granted summary judgment for the Department. The Supreme Court affirmed, holding that the Department’s Medicaid lien was valid as to the properties. View "Gheen v. State ex rel. Dep’t of Health" on Justia Law

Erin Clements was injured at work and received temporary total disability (TTD) benefits for twelve months. Clements subsequently obtained an extension of TTD benefits for the statutory maximum of twelve months. When Clements applied for additional TTD benefits, the Worker’s Safety and Compensation Division denied her claim because she had received all the TTD benefits to which she was entitled under Wyoming law and Division rules. Clements filed a declaratory judgment action seeking a declaration that the Division exceeded its authority when it limited the extension of TTD benefits to twelve months. The district court granted declaratory relief. The Supreme Court affirmed, holding that the Division exceeded its authority when it adopted a rule setting a maximum number of months TTD benefits are payable under any circumstances. View "State ex rel. Dep’t of Workforce Servs. v. Clements" on Justia Law

In 1994, Appellant suffered modest physical injuries while working as a psychiatric aide at the Wyoming State Hospital. Four years later, Appellant was denied permanent total disability (PTD) benefits. Appellant continued seeking medical treatment. Appellant reapplied for PTD benefits in 2009, but the Wyoming Workers’ Safety and Compensation Division denied her claim. After a case hearing, a panel of the Medical Commission denied the subsequent application for PTD benefits, concluding that Appellant’s only disabling condition was psychological and not related to any compensable physical injury. The district court affirmed. The Supreme Court affirmed, holding that the Commission reasonably concluded that Appellant did not establish entitlement to PTD benefits under the Wyoming Workers’ Compensation Act or the odd lot doctrine, and the Commission’s conclusions were in accordance with applicable law. View "In re Worker's Comp. Claim of Hathaway" on Justia Law

After the Department of Family Services (DFS) received reports regarding the care Children were receiving from Mother and Stepfather, the State filed a neglect petition. DFS’s efforts to reunify Children with Mother failed. The juvenile court subsequently ordered Children to remain in the custody of Father and that DFS move to terminate the parental rights of Mother to Children. DFS appealed, claiming it could not move to terminate Mother’s parental rights because it did not have custody of Children and therefore was not an “authorized agency” that may file a petition to terminate one’s parental rights. The Supreme Court affirmed, holding that DFS was an “authorized agency” under the relevant statute regardless of whether it had physical and/or legal custody of Children. View "In re LB" on Justia Law

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