Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of attempted first-degree murder, kidnapping, and aggravated assault and battery after he attacked the victim and hit her in the face and body with a sledgehammer. The Supreme Court affirmed the convictions, holding (1) the district court did not abuse its discretion by admitting evidence of Appellant's previous violent behavior against the victim; (2) the district court did not abuse its discretion when it allowed a transcript of a telephone conversation between Appellant and the victim to be reviewed by the jury while the recording was being played at trial; and (3) Appellant did not receive ineffective assistance of counsel because defense counsel requested a continuance and waived Appellant's right to a speedy trial. View "King v. State" on Justia Law

After entering a construction contract with Appellants, Appellee filed a breach of contract and unjust enrichment action against Appellants. Appellants counterclaimed for breach of contract. The Supreme Court (1) affirmed the district court's judgment against Appellants with respect to Appellee's claims under the Prime Contract Change Order (PCCO) Nos. 1 and 2; (2) reversed the district court's order dismissing Appellee's claims relating to PCCO Nos. 3 and 4; and (3) affirmed the district court's dismissal of Appellants' counterclaims. Following remand, the district court (1) granted Appellee's motion to dismiss its remaining claims; and (2) dismissed all counterclaims of Appellants, declaring them to be moot. Appellants appealed, contending that the district court erred in dismissing their counterclaims and denying their request for costs and attorney's fees. The Supreme Court affirmed, holding that they district court did not abuse its discretion by (1) dismissing Appellant's counterclaims, as Appellee's dismissal of its claims rendered any contractual defense to the claims moot; and (2) declining to award costs and attorneys fees to Appellants, as Appellants could not be correctly classified as the prevailing party. View "Sterrett Props., LLC v. Big-D Signature Corp." on Justia Law

After his conviction, Appellant was sentenced to a term of imprisonment. After Appellant was sentenced, the State successfully filed a motion to correct Appellant's sentence, which was illegal, by increasing the maximum term by three months. Appellant later filed successive motions to reduce his sentence, both of which were denied. Thereafter, Appellant filed a motion to correct illegal sentence, arguing that his original sentence was illegal and asserting that his sentence had been increased without notice or an opportunity to be heard in violation of his constitutional rights. The district court set aside the order increasing Appellant's sentence and reinstated Appellant's original sentence. The Supreme Court vacated Appellant's sentence, concluding that while the increased sentence was correctly set aside, the original sentence was illegal and could not be reimposed. On remand, Appellant raised a speedy sentencing issue. The district court denied relief with respect to the speedy sentencing issue and imposed a new sentence. The Supreme Court affirmed the amended judgment and sentence, holding (1) there was no violation of Appellant's right to a speedy trial; (2) Appellant's correct sentence was legal; and (3) Appellant's double jeopardy rights were not violated when his sentence was increased by three months after he had begun serving it. View "Patterson v. State" on Justia Law

After a jury trial, Appellant was convicted of violating Wyo. Stat. Ann. 6-2-303(a)(vi) and 6-2-303(a)(viii), each proscribing, in the disjunctive, sexual assault in the second degree. The district court sentenced Appellant to concurrent sentences of not less than three nor more than five years incarceration. The Supreme Court affirmed in all respects excepting the propriety of permitting two convictions to stand, holding (1) the evidence was sufficient to establish Appellant was in a position of authority as required by section 6-2-303(a)(vi); (2) the prosecutor did not engage in prosecutorial misconduct; and (3) the constitutional prohibition against double jeopardy required that the Court vacate one of the two convictions under disjunctive provisions of one statute when both convictions rested upon the same criminal act. Remanded for entry of a new judgment and sentence convicting Defendant of one violation of section 6-2-303 and imposing one sentence. View "Solis v. State" on Justia Law

Pursuant to an oral agreement with Defendant, Plaintiff kept his beefalo cattle herd on Defendant's ranch. After a dispute arose between the parties regarding the oral agreement, Defendant asserted a lien for payments allegedly owed under the oral agreement. Plaintiff filed a complaint and petition for release of his cattle, asserting that the lien was knowingly false and groundless and that Defendant wrongfully converted the beefalo herd. The jury found that Defendant was liable for conversion of Plaintiff's cattle but that Defendant was entitled to the lien claimed for feed and pasturage from the time Defendant asserted the lien on the cattle until their court-ordered release. Defendant filed a motion for a new trial, claiming the verdict was inconsistent because he could not be liable for conversion of Plaintiff's beefalo herd if he was entitled to a lien against the same. The district court denied Defendant's motions and entered a final judgment incorporating the jury's verdict. The Supreme Court reversed, holding that the district court abused its discretion in denying Defendant's motion for new trial because the verdict was contrary to law and could not be reconciled. Remanded for a new trial. View "McTiernan v. Jellis" on Justia Law

Mother, a U.S. citizen, and Father, a citizen of both France and the U.S., were married in Teton County after executing a prenuptial agreement. The parties subsequently became the parents of twins. In 2011, Mother filed for divorce in the Teton County district court. Father then moved to France. The trial court entered a decree that divided the parties' property in accordance with the prenuptial agreement and awarded Mother sole custody of the children. The Supreme Court affirmed, holding that the district court did not err in (1) determining that it had jurisdiction to resolve the parties' custody dispute; and (2) declining to assign any significant weight to the children's possible dual citizenship in making its custody and visitation determination. View "Harignordoquy v. Barlow" on Justia Law

After Joan Marusich died, the State ex rel. Department of Health, Office of Healthcare Financing/Equalitycare (Department) filed a lien against the home Joan owned as tenants by the entirety with her husband, William Marusich, who predeceased Joan. The Department filed the lien to recover the cost of Medicaid benefits paid on behalf of William. Joan's Estate filed a petition against the Department to remove a false lien. The district court granted summary judgment against the Estate on the validity of the lien. After the district court entered a final judgment on the amount of the lien, the Estate appealed. The Supreme Court affirmed, holding (1) the district court correctly granted summary judgment upholding the Department's lien; and (2) the district court did not abuse its discretion by denying the Estate's motion to amend the petition. View "Estate of Marusich v. State ex rel. Dep't of Health, Office of Healthcare Fin./Equalitycare" on Justia Law

After a jury trial, Defendant was convicted of felony possession of cocaine and misdemeanor possession of marijuana. Defendant appealed, contending that the trial court erred in refusing his request to introduce Chauncey Swain's out-of-court statements that the cocaine belonged to him under the "statement against interest" exception to the hearsay rule. The Supreme Court affirmed, holding that Swain's statements were properly excluded as inadmissible hearsay where the district court properly weighed the factors and concluded that Defendant did not present sufficient corroborating circumstances to establish the trustworthiness of Swain's statements under Wyo. R. Evid. 804(b)(3). View "Moore v. State" on Justia Law

Richard Reynolds filed a complaint against Christopher Bonar, claiming personal injuries arising from a motor vehicle accident. Bonar later filed a motion for sanctions for Reynolds' failure to comply with discovery, which the district court granted. Thereafter, Bonar filed a motion to dismiss based on Reynolds' failure to comply with the court's order. The district court granted Bonar's motion and dismissed the complaint without prejudice. Reynolds subsequently re-filed his complaint against Bonar. The district court later dismissed Reynolds' complaint with prejudice for failure to comply with discovery. The Supreme Court affirmed, finding no constitutional violation in the district court's dismissal of Reynolds' complaint with prejudice. The Court also imposed sanctions upon Reynolds. View "Reynolds v. Bonar" on Justia Law

This case concerned Merit Energy Company's 2006 natural gas severance and ad valorem tax liability for wells located in several counties. Merit was a take-in-kind interest owner, which is a party who elects to take a portion of the mineral produced rather than receive monetary remuneration for its share of the production. The State Board of Equalization (SBOE) determined that Merit failed to timely appeal several final Wyoming Department of Revenue (DOR) decisions regarding the amount of taxable gas it had received and dismissed Merit's appeal. The district court affirmed. The Supreme Court affirmed, holding (1) the district court did not err in affirming the SBOE's dismissal as untimely; and (2) even if the Court permitted Merit to appeal the notice of valuation change sent by the DOR, the doctrine of collateral estoppel precluded Merit from doing so. View "Merit Energy Co. v. Dep't of Revenue" on Justia Law