Justia Wyoming Supreme Court Opinion Summaries

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

Appellant pleaded guilty to two counts of failure to register as a sex offender. The district court sentenced Appellant to concurrent sentences of two to four and four to six years but suspended the sentences and imposed eight years probation. After Appellant violated the terms of his probation, the district court revoked Appellant’s probation and reimposed the suspended sentence. Appellant subsequently pled guilty to escape and was sentenced to three to seven years suspended in favor of four years probation to be served consecutively to the separate reimposed sentence. Thereafter, Appellant filed a motion to correct an illegal sentence, arguing that the district court was without the authority to “mix a sentence of imprisonment and probation.” The district court denied the motion. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it sentenced Appellant to a period of imprisonment followed by a period of probation. View "Askin v. State" on Justia Law

The Department of Family Services filed a petition to terminate Mother’s rights to her son. A default was entered against Mother after she failed to answer the Department’s petition. During a recess in the default termination hearing, Mother provided a signed and acknowledged relinquishment of her parental rights and consent to adoption of her son. The district court entered an order accepting the relinquishment and consent. Mother appealed, arguing that the district court erred in not setting aside the default and in accepting the relinquishment and consent. The Supreme Court dismissed the appeal, holding (1) Mother’s decision to provide the relinquishment and consent rendered any claimed error in declining to lift the default moot; and (2) the order accepting the relinquishment and consent was not appealable. Remanded. View "V.L.K. v. State" on Justia Law

After a jury trial, Appellant was convicted of several criminal offenses, including attempted second-degree murder. The district court sentenced Appellant to thirty to forty years for the attempted murder conviction with lesser sentences to run concurrently. The district court subsequently denied Appellant's motion for sentence reduction and Appellant's ensuing motion for reconsideration. The Supreme Court affirmed the denial of Appellant's motions, holding (1) the district court did not abuse its discretion in denying Appellant's motion for reduction of sentence; (2) the district court did not violate Appellant's due process rights by denying Appellant's motion to reconsider a sentence reduction; and (2) the State did not commit prosecutorial misconduct by misstating facts in its traverse to Appellant's motion for reduction of sentence. View "Sanchez v. State" on Justia Law

Appellant entered Alford pleas to two felony counts of obtaining public welfare benefits by misrepresentation. Appellant initially pled not guilty to the charges. Appellant appealed, arguing, among other things, that the district court erred when it failed to advise her that a guilty plea to the felonies with which she was charged could result in the loss of her right to possess firearms and her ability to be employed in professions that require carrying and using firearms. The Supreme Court reversed Appellant's conviction and remanded with instructions to reinstate her not guilty plea because the district court did not provide the required statutory firearms advisement when Appellant changed her plea. View "McEwan v. State" on Justia Law

When the Union and the City entered into negotiations regarding the 2012-2013 wages and other employment terms for the City's fire department members, the City included in its negotiating team the mayor, one city council member, and other members of the City's administration and staff. The Union eventually filed a declaratory judgment seeking a ruling that a quorum of the city council was required to negotiate with the Union, the City could not unilaterally decide to conduct the negotiating sessions in public, and the proposals exchanged by the parties were not public records. The district court granted summary judgment declaring that a quorum of the city council was not obligated to participate in the negotiations and that the other two issues were not justiciable. The Supreme Court reversed in part and affirmed in part, holding that the statutes mandate a quorum of the city council to negotiate with the Union and that the other two issues were not justiciable. View "Int'l Ass'n of Firefighters Local Union No. 279 v. City of Cheyenne" on Justia Law