Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of a single count of felony larceny. The Supreme Court affirmed the conviction and sentence, holding (1) any deficiency in Defendant's trial attorney's failure to challenge a certain juror for cause was not prejudicial, and therefore, counsel did not provide constitutionally ineffective assistance; (2) the district court did not abuse its discretion in failing to grant Defendant's motion for a new trial based on the claim that another juror was mentally incompetent; and (3) Defendant could not prevail on his claim that the cumulative effect of the alleged errors warranted reversal of his conviction, as the doctrine did not apply in this case. View "Moore v. State" on Justia Law

Husband and Wife were married for seventeen years at the time they decided to divorce. After a trial, the district court (1) valued the total assets to be divided between the parties at approximately $4.5 million; (2) awarded Wife over $1 million and (3) awarded Husband approximately $3.4 million. Wife appealed arguing that the trial court inequitably divided the marital assets when it gave her only twenty-three percent of the total assets. The Supreme Court affirmed, holding that the district court properly assessed the facts and considered each of the required factors in making its determination and thus did not abuse its discretion in dividing the marital property. View "Kummerfeld v. Kummerfeld" on Justia Law

In KMO I, the district court terminated Mother's parental rights, and the Supreme Court affirmed. Mother's appointed attorney on appeal (Attorney) filed a fee motion requesting $121,530 in fees. The district court awarded attorney's fees in the amount of $25,000, concluding that it could not, "in good conscience," award attorney's fees in the amount Attorney requested. Attorney appealed. The Supreme Court affirmed the district court's fee reduction in this case, holding that Attorney provided no evidence demonstrating that the fee reduction was unreasonable, and the district court did not err in its assessment of the fee request. View "In re KMO" on Justia Law

While she was working as a nurse at a hospital, Appellant suffered a heart attack. The Wyoming Workers' Safety and Compensation Division denied Appellant's claim for benefits. The Office of Administrative Hearings (OAH) upheld the Division's denial of benefits, concluding that Appellant failed to prove her myocardial infarction was caused by exertion clearly unusual or abnormal to her position at the hospital. The Supreme Court affirmed, holding that the OAH did not err when it interpreted the statute governing coronary conditions to require that the causative exertion be unusual or abnormal for her position at the hospital rather than unusual or abnormal in the nursing profession generally. View "Fieseler v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Appellant was convicted of eleven counts of burglary. At his arraignment, Appellant peremptorily disqualified Judge Kalokathis and the case was assigned to a different judge. After Defendant was convicted, the case was again assigned to Judge Kalokathis for sentencing. Judge Kalokathis sentenced Appellant to a total of forty-four to eighty-eight years but later vacated Appellant's sentence because he had previously been disqualified. Judge Grant was assigned the case for resentencing and sentenced Appellant to a total of fifty-two to seventy-five years. Appellant's convictions were affirmed on appeal. Appellant later filed a motion to correct an illegal sentence, asserting that Judge Grant improperly increased the original sentence in violation of his due process rights. The district court denied Appellant's due process claim. The Supreme Court affirmed, holding (1) Appellant's claims were barred by the doctrine of res judicata because Appellant failed to raise them in the direct appeal from his convictions; and (2) Appellant's sentence on resentencing did not violate his constitutional due process and double jeopardy protections. View "Ferguson v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and aggravated assault and battery. Defendant appealed both convictions and requested remand for a hearing on his claim that trial counsel was ineffective because they failed to call expert witnesses to substantiate his claim of self-defense. The Supreme Court granted Defendant's request. On remand, the district court concluded that Defendant's trial counsel performed deficiently but that Defendant was not prejudiced by the deficient performance. On appeal, the Supreme Court reversed Defendant's convictions, holding that the prosecution engaged in misconduct, and, given the numerous errors on the part of the prosecution, both of Defendant's convictions were tainted. Remanded for retrial. View "Drennen v. State" on Justia Law

Appellant was charged with three crimes for his sexually-charged attack on his sister-in-law. The morning trial was to begin, the district court allowed the State to amend to Information to clarify that one of the charges was for aggravated burglary, not simply burglary. After a jury trial, Appellant was convicted of aggravated burglary, battery, and third-degree sexual assault. Appellant appealed, arguing that the district court erred by permitting amendment of the aggravated burglary charge. The Supreme Court affirmed, holding that the district court did not abuse its discretion or deprive Appellant of his due process rights by granting the State's motion to amend the Information before trial began. View "Albarran v. State" on Justia Law

Mother was the primary residential custodian of Daughter under Mother and Father's divorce decree. Father subsequently filed a motion seeking primary residential custody of Daughter. Mother opposed the change of custody and sought an increase in child support based on a purported increase in Father's income. The district court (1) denied Father's motion for a change of custody, finding no material change in circumstances; and (2) granted Mother's request for an increase in child support. The Supreme Court (1) reversed the child support order and remanded for entry of a proper award, holding that the amount of the child support awarded was not correct under Wyoming's statutory child support tables; and (2) affirmed on all other issues. View "Walker v. Walker" on Justia Law

In 2008, Husband and Wife were divorced pursuant to a stipulated property settlement, child custody, child support agreement. In 2010, Husband petitioned to reopen the divorce decree, alleging that Wife had misrepresented material facts related to the parties' division of debt. After an evidentiary hearing, the district court denied Husband's petition, concluding that any misrepresentation by Wife about certain loans was insufficient to reopen the decree of divorce. The Supreme Court affirmed, holding that while Wife may have made misrepresentations concerning the loans, the district court did not abuse its discretion in finding that the debt allocation to Wife did not result in an overall allocation of debt that was mistaken or unfair. View "Campbell v. Hein" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to commit burglary. Defendant appealed, contending that the district court erred by refusing to order one of his co-conspirators to submit handwriting exemplars so that Defendant's expert witness could analyze whether the co-conspirator was the author of certain notes sent in jail. The district court concluded that there was no legal authority to require a non-party to appear before trial to provide handwriting exemplars. The Supreme Court disagreed with the district court but affirmed, holding (1) the subpoena procedure may be used to order a witness to provide handwriting exemplars; but (2) any error regarding Defendant's right to obtain handwriting exemplars from his co-conspirator was harmless beyond a reasonable doubt. View "West v. State" on Justia Law