Justia Wyoming Supreme Court Opinion Summaries

Wife filed a complaint for divorce from Husband. The district court granted Wife a divorce and distributed all of the property between Husband and Wife. Wife subsequently appealed the property distribution in the divorce decree, asserting that the district court abused its discretion when it divided the property contrary to the evidence presented at trial and when it failed to consider the financial condition in which the parties were left after the divorce. The Supreme Court affirmed and awarded Husband his costs and attorney's fees associated with this appeal, holding (1) Wife failed to comply with Wyo. R. App. P. 3.02(b) by failing to provide the Court with a transcript of the district court proceedings; (2) because the Court could not review the evidence, it could not find that the district court abused its discretion in how it divided the parties' property; and (3) because there was no transcript in the record, the Court could not certify that there was reasonable cause to bring this appeal. View "Golden v. Guion" on Justia Law

After an adjudicatory hearing in this abuse and neglect case, Appellant was found to have neglected her three children. Appellant appealed, arguing that she was denied fundamental due process rights because the trial court declined to grant a motion to dismiss or to strike witnesses after claimed discovery violations by the State and because the evidence was insufficient to support a finding of neglect. The Supreme Court affirmed, holding (1) the trial judge did not abuse his discretion in dealing with the claimed discovery violations; (2) Appellant received due process; and (3) the evidence was sufficient to support a finding of neglect. View "DL v. State, Dep't of Family Servs." on Justia Law

The Thornhocks filed an action against the Esterholdts and others seeking to quiet title to certain lands in Lincoln County. The district court granted summary judgment to the Thornocks as to some of the land but denied summary judgment as to a certain strip of property. After a bench trial, the district court quieted title in the disputed strip of land in the Esterholdts. The Supreme Court affirmed, holding (1) an appurtenant easement was not created by a deed that granted, in addition to tracts of fee title land, also that "right of way to be used in connection with said land"; and (2) an appurtenant easement was not created by a deed that granted a "right-of-way" described as the land now in question. View "Thornock v. Esterholdt" on Justia Law

Defendant was convicted of two counts of first degree sexual abuse of a minor and one count of second degree sexual abuse of a minor upon his three daughters. Defendant appealed. The Supreme Court affirmed, holding (1) the prosecutor did not commit misconduct when he questioned a witness about an exhibit that he did not intend to submit into evidence; (2) as to two of the victims, there was not a fatal variance between the charges in the information and the charges proven at trial, and the evidence was sufficient to support the convictions; and (3) the trial court did not abuse its discretion when it prohibited Defendant's expert witness from testifying about his opinion on what type of sexual abuse allegations were made in this case, as the proposed testimony fell outside the range of permissible opinion testimony. View "Craft v. State" on Justia Law

Appellant injured her neck and shoulder in a work-related accident. The Workers' Safety and Compensation Division approved Appellant's application for temporary total disability benefits but denied payments of two medical bills related to Appellant's lower back, concluding that the case was only left open for shoulder and neck injury. The office of administrative hearings (OAH) upheld the Division's denial of benefits. Appellant appealed. While on review in the district court, Appellant's counsel discovered documentation of a physical therapy session held approximately one month after Appellant's workplace accident that indicated she was experiencing pain in the middle of her back. Appellant unsuccessfully filed a motion to supplement the record with the physical therapy record. Appellant subsequently dismissed her appeal. Appellant then filed a Wyo. R. Civ. P. 60(b) motion for relief from final judgment based on the physical therapy record. The OAH denied the motion. The district court affirmed. The Supreme Court affirmed, holding (1) Appellant provided no evidence to support her claim that the failure to introduce the physical therapy record was caused by her trial counsel's mistake or inadvertence, and (2) Appellant failed to prove the significance of the medical record to her claim for benefits relating to her low back. View "Tegeler v. State ex rel. Workers' Safety & Comp. Div" on Justia Law

After a jury trial, Appellant was convicted of four counts of sexual abuse of a minor in the second degree. Appellant appealed, complaining that the prosecutor engaged in improper misconduct and that he was denied a fair trial as a result of the violation of his right against self-incrimination caused by the deficient assistance of counsel. The Supreme Court affirmed, holding (1) Appellant failed to demonstrate that the questions asked by the prosecutor were so harmful and prejudicial that any unfairness or injustice occurred; and (2) trial counsel did not render ineffective assistance for not objecting to a presentence investigation and for failing to advise Appellant that he need not submit to such an investigation. View "Leonard v. State" on Justia Law

In 2006, Teton County voters approved a Teton County Housing Authority (TCHA) sponsored ballot initiative enabling a specific purpose excise tax (SPET) to raise $5 million for TCHA's affordable housing program. In 2007, TCHA purchased a five-acre property on Cheney Lane. Later that year, Plaintiffs, residents of the Cheney Lane neighborhood, initiated a declaratory judgment action against TCHA, alleging violations of SPET limitations, breach of investment duties, and violations of Wyoming statutory limits on public financing. Two weeks after the district court heard arguments on the motion to dismiss, the Village Road Coalition (VRC), a nonprofit corporation consisting of residents of a neighborhood near the Cheney Lane property, filed a motion to intervene. The district court denied the motion. The court subsequently granted TCHA's motion to dismiss the complaint for lack of standing. The Supreme Court affirmed, holding (1) because VRC's interests and relief sought were duplicative of those presented by Plaintiffs, the district court did not err in denying the motion to intervene; and (2) the district court properly dismissed TCHA's action for lack of standing, as Plaintiffs failed to allege a tangible interest that had been harmed by the acquisition of the property. View "Village Road Coal. v. Teton County Hous. Auth." on Justia Law

In 2001, Plaintiff offered to purchase a commercial property. Defendant was the real estate agent who prepared the offer. The sellers accepted the offer to purchase and prepared a property disclosure statement in compliance with the contract requirement. Plaintiff became the sole owner of the property in 2004. Two years later, Plaintiff discovered three inches of water in the building basement that had leaked through the west wall of the foundation of the building. In 2012, Plaintiff filed a complaint against Defendant, alleging he was negligent in failing to provide the property disclosure statement. The district court dismissed the action on account of the two-year statute of limitations having expired. Plaintiff appealed, arguing that the district court erred in ruling that Defendant had no duty to disclose or provide the property disclosure statement. The Supreme Court dismissed the case due to Plaintiff's failure to challenge the statute of limitations ruling by the district court. The Court also noted that the district court acknowledged that Defendant owed Plaintiff a duty to deliver the disclosure statement. View "Ferrell v. Knighten" on Justia Law

Sheridan Fire Fighters Local No. 276 filed suit against the City of Sheridan alleging that the City breached the parties' collective bargaining agreement when it failed to provide pay raises to five firefighters who had qualified for a "step increase" in salary. The City responded that the raises were not required and that, under the terms of the agreement, the City retained discretion in the award of pay raises. The district court granted summary judgment for the City. The Supreme Court reversed and remanded for entry of summary judgment in favor of Local 276, holding (1) the agreement was ambiguous about whether step increases in salary were mandatory or left to the City's discretion; and (2) because Local 276 presented evidence in support of its summary judgment motion consistent with the union's interpretation that the agreement required the City to give step increases to all eligible firefighters, and the City offered no evidence to the contrary, there were no genuine issues of material fact, and Local 276 showed it was entitled to judgment in its favor. View "Sheridan Fire Fighters Local No. 276 v. City of Sheridan" on Justia Law

Appellant pled guilty to unlawful use of a credit card (a misdemeanor) and forgery (a felony). The district court denied Appellant's motions to modify his sentence, correct an illegal sentence, and reduce his sentence. Appellant unsuccessfully filed a motion for postconviction relief and another motion for a reduction of his sentence. Finally, Appellant filed a motion to correct an illegal sentence based on the same allegations he raised in the petition for postconviction relief, namely, that he was denied a direct appeal, that he received ineffective assistance of counsel, and that the prosecutor engaged in misconduct. The district court denied the motion. Appellant appealed, arguing that his sentence was illegal because he was not advised that his guilty pleas may result in the disqualification of his right to possess firearms pursuant to federal law. The Supreme Court affirmed, holding that the Court could not consider Appellant's argument because it was being raised for the first time on appeal, and further, even if the issue had been raised before the district court, it would have been barred by the doctrine of res judicata. View "Lunden v. State" on Justia Law