Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of felony interference with a peace officer. The conviction arose from an incident in which Defendant kicked an officer in the chest, causing him to fall backward onto asphalt pavement. On appeal, Defendant challenged the sufficiency of the evidence, contending that the evidence that the officer was injured by his actions was insufficient to support the conviction. The Supreme Court affirmed the conviction, holding that, in this case, the jury could have reasonably concluded that the State proved beyond a reasonable doubt that the officer was injured when Defendant kicked him. View "Grimes v. State" on Justia Law

Petitioners petitioned to be appointed permanent guardians of their elderly uncle, Thomas Lankford. The district court dismissed the guardianship petition after finding Petitioners were not qualified to serve as guardians because their potential to inherit from Lankford created a disqualifying conflict of interest. Petitioners appealed, asserting (1) the district court erred in finding a conflict of interest, and (2) in the alternative, the guardianship conflict waiver statute, which allows a court of waive conflicts but limits that authority to conflicts of a spouse, adult child, parent, or sibling of a ward, violated their due process and equal protection rights. The Supreme Court affirmed, holding (1) the district court did not err in finding a conflict of interest; and (2) Petitioners' constitutional claims were not properly before the Court. View "Utley v. Lankford" on Justia Law

Plaintiffs owned property that was conveyed by warranty deed to J.A. Reed. In 1968, Reed conveyed the property to Julianne Biggane, and in 2006, the Biggane Trust transferred the property to Plaintiffs. Prior to Reed's transfer of the property to Biggane, a pole line easement across the property was granted to PacifiCorp's predecessor in interest. Reed, however, signed the easement grant as president of Continental Live Stock Company, rather than in his personal capacity, at a time that the company had no interest in the underlying land. Therefore, the easement was a "wild deed." At issue before the Supreme Court was whether a "wild deed" can be the "root of title" under the Wyoming Marketable Title Act. This case arose when Plaintiffs filed an action seeking to have the easement declared invalid because it emanated from a wild deed. The district court held that the Act validated PacifiCorp's easement across Plaintiffs' property. The Supreme Court affirmed, holding that a wild deed may constitute the root of title under the Act, and a wild deed serving as a root of title that does not bear a defect "on its face" is not an "inherent defect" in the chain of record title under the Act. View "Esterholdt v. PacifiCorp" on Justia Law

Western Wyoming Construction Company (WWC) submitted a bid for a highway project in Sublette County. The Board of County Commissioners of Sublette County (Commissioners) awarded the contract to another resident contractor whose bid was higher than WWC's. WWC filed a complaint in district court for an order awarding it the contract for the project. The district court granted summary judgment in favor of the Commissioners. At issue on appeal was whether Wyo. Stat. 16-6-102(a) required the Commissioners to award the contract to the responsible certified Wyoming resident making the lowest bid. The Supreme Court reversed, holding (1) section 16-6-102 has no application in the context of two resident contractors; and (2) because no evidence was presented showing where the funds came from to pay for the project, (i) there could be no finding as to what statutory provision, if any, was applicable, and (ii) a judicial determination as to the appropriateness of the bid award was not possible. Remanded. View "W. Wyo. Constr. Co., Inc. v. Bd. of County Comm'rs" on Justia Law

The Wyoming Workers' Safety and Compensation Division awarded benefits to Appellant after he experienced a workplace injury. The Division denied Appellant's claim for payment for prescription medication he alleged was related to his workplace injury. The Medical Commission upheld the Division's determination, and the district court affirmed. The Supreme Court affirmed, holding (1) the Commission's decision upholding the Division's denial of benefits was supported by substantial evidence; and (2) the Commission applied the proper burden of proof for a second compensable injury when it required Appellant to establish a causal connection between his abdominal pain and his ingestion of the prescription medication at issue. View "Jacobs v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

In 2010, the director of the Wyoming Guardianship Corporation filed a petition for emergency appointment of a temporary guardian for Robert Sands, who was then seventy years old and suffered from dementia and other medical problems. The district court held a guardianship was necessary and appointed Richard Brown as guardian. Sands sought to terminate the guardianship, and the district court denied the petition. Six months later, however, the district court held a review hearing and terminated the guardianship, finding there was no longer a need for the guardianship. Prior to the hearing, Sands filed a complaint against Brown, alleging that Brown had breached his duties. The district court ruled in favor of Brown on Sands' complaint, concluding that Brown substantially complied with the statutes and did not violate his fiduciary duties, and awarded Brown and his attorney fees and costs. The Supreme Court affirmed, holding that the district court did not err in when it denied Sands' petition to terminate the guardianship, reopened the guardianship for the purpose of awarding fees and costs, and dismissed Sands' complaint against Brown. View "Sands v. Brown" on Justia Law

Appellant was charged while driving under the influence. The Wyoming Department of Transportation suspended Appellant's driver's license. Appellant appealed, arguing that she had not been properly advised as to implied consent. The Office of Administrative Hearings upheld the suspension. Appellant sought review of the administrative suspension in the district court, raising a number of constitutional challenges to a municipal criminal ordinance in addition to the claim that she had not been properly advised under the implied consent statute. The district court concluded (1) the constitutional issues raised by Appellant had not and could have been raised in the administrative hearing, and therefore, the court lacked jurisdiction to consider the claims; and (2) Appellant was properly advised as to implied consent. The Supreme Court affirmed, holding (1) the hearing officer correctly determined that Appellant was properly advised as required by statute; and (2) Appellant's other claims were not and could have been presented in a license suspension proceeding. View "Walters v. State ex rel. Wyo. Dep't of Transp." on Justia Law

After a jury trial, Appellant was convicted of felony stalking. Appellant appealed, contending (1) the amended information did not allege sufficient facts to constitute the offense of felony stalking and did not adequately inform him of the charges against him; and (2) the jury was not adequately instructed with respect to the intent element of the crime. The Supreme Court reversed and remanded for a new trial, holding (1) the district court did not err in permitting the State to amend the information; (2) Appellant was not denied his constitutional right to adequate notice of the charge he was required to defend against; but (3) the district court plainly erred by providing a confusing and misleading jury instruction that combined two of the elements of stalking, and the error in the jury instructions caused prejudice to Appellant. View "Walker v. State" on Justia Law

Appellant pled guilty to attempted second degree murder in an oral plea agreement and was sentenced to a term of twenty-five to fifty years in prison. The district court also awarded restitution. Appellant later removed to withdraw his plea, claiming that his attorney conspired with the court, misled him about the term he would serve, and coerced him into pleading guilty. The district court denied the motion, concluding that Appellant failed to demonstrate manifest injustice. Appellant appealed, claiming the district court abused its discretion in denying his motion to withdraw his guilty plea and in awarding restitution. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it denied Appellant's motion to withdraw his guilty plea; and (2) the district court had authority to award restitution and to waive public defender fees. View "Chapman v. State" on Justia Law

Father and Mother divorced in 1990. The parties agreed that each parent would have custody of one child. In 1999, the parties stipulated to a modification of their divorce decree, agreeing that Father would have primary custody of both children. The district court ordered that the parties file further information as to child support, but neither party responded. The case remained inactive until 2003, when Father filed a motion for order to appear and show cause, requesting that the district court order Mother to pay her half of the children's expenses. The court ordered Mother to pay child support and certain related expenses. In 2009, the Wyoming Department of Family Services (Department) filed an action to enforce the 2003 order. Instead of enforcing the order, the district court set it aside, ordered that the child support obligation be recalculated, and directed that the revised child support obligation be applied retroactive to 1999. The Supreme Court reversed, holding that the district court was without jurisdiction to modify the 2003 child support order where no petition to modify had been filed. Remanded. View "State, Dep't of Family Servs. v. Powell" on Justia Law