Justia Wyoming Supreme Court Opinion Summaries

While a lawsuit by Appellees David and Elizabeth Speaks was pending against Rosemary and Byron Baker for damages related to poor construction workmanship, the Bakers transferred two parcels of real property to their son, Nathan Baker. The case resulted in a judgment against Byron but a dismissal of the claims against Rosemary. The appellate court affirmed the trial court's decision. Five days later, Nathan transferred the properties to a limited liability company (LLC) he and his family controlled. Appellees subsequently filed this case under the Uniform Fraudulent Conveyance Act and the Uniform Fraudulent Transfer Act. While the case was pending, the LLC transferred the two pieces of property to trusts controlled by Rosemary Baker. The district court granted summary judgment for Appellees permitting execution on the properties, finding that all of the conveyances were fraudulent. The Supreme Court reversed and remanded, holding (1) the district court correctly found the conveyances to be fraudulent; but (2) Appellees failed to make the required prima facie showing that the properties were subject to execution on a judgment against Byron Baker alone. View "Baker v. Speaks" on Justia Law

Appellant was the mother of LNP. After Grandparents took LNP into their care, they petitioned for temporary guardianship of LNP, which the district court granted. Grandparents subsequently moved to convert the temporary guardianship to a plenary guardianship. In response, Appellant filed a motion to terminate the temporary guardianship. Mother then filed a motion to vacate the temporary guardianship, alleging that LNP was an Indian child as defined by the Indian Child Welfare Act (ICWA) and that the court had failed to comply with the provisions of the ICWA in granting the temporary guardianship. After a hearing, the district court granted the guardianship petition and denied Appellant's request to terminate the guardianship. The Supreme Court affirmed, holding that, in holding the hearing, district court (1) did not comply with the ICWA's ten-day notice requirement, but the error was harmless; (2) received testimony from a qualified expert witness as required by the ICWA; and (3) received clear and convincing evidence that showed LNP's return to Appellant would likely result in serious emotional or physical damage as required by the ICWA. View "In re Guardianship of LNP" on Justia Law

The Wyoming Workers' Safety and Compensation Division determined that Appellant suffered a compensable injury while employed by Employer. The lodge filed an objection to that determination and requested a hearing with the Office of Administrative Hearings (OAH). Appellant filed a motion to dismiss that objection on the grounds that the objection was invalid because Employer was not a proper party to the action. The OAH denied Appellant's motion and concluded that Appellant had not suffered a compensable injury. The district court affirmed. At issue on appeal was whether Employer properly filed an objection to the Division's final determination of compensability. The Supreme Court affirmed, holding that Employer was a proper party to the action because it was the identified employer and paid the necessary contributions under Wyoming Worker's Compensation Act. View "Heikkila v. Signal Mountain Lodge" on Justia Law

In a shareholder meeting of a corporation (Corporation), Appellee was the only shareholder present at the meeting. Appellee concluded that a quorum existed and thus voted upon and passed several resolutions, including replacing his estranged wife, Appellant, as the corporation's secretary. Appellant filed a complaint to set aside the corporate action that occurred at the shareholder meeting. The trial court held (1) jointly held stock held by Appellee and Appellant could be counted for purposes of a quorum of shareholders in the absence of either personal attendance or a proxy from both owners, and (2) the resolutions were passed with requisite authority. The Supreme Court affirmed, holding (1) the district court was correct in holding that the shares of stock co-owned by Appellee and Appellant as husband and wife were "entitled to vote" pursuant to the bylaws of Corporation, the court was correct in its characterization of Appellee and Appellant holding the stock as tenants by the entirety, and because of the stock's representation in person at the shareholder meeting, the stock could be counted for quorum purposes; and (2) consequently, the resolutions of the shareholder meeting were passed with requisite authority. View "Case v. Sink & Rise, Inc." on Justia Law

In 2008, the district court entered a default judgment and order establishing Father's paternity of a child and ordering him to pay child support. In 2011, the Department of Family Services (DFS) filed a petition for an order to show cause as to why Father should not be held in contempt of court for failing to pay child support. After Father requested counsel, the district court appointed counsel to represent Father. DFS objected to the court's order appointing counsel. The district court denied DFS's objection, ruling that due process required the state to provide an indigent party with counsel in a civil contempt proceeding for non-payment of child support when incarceration was one of the possible penalties. The Supreme Court reversed, holding that appointment of counsel was not required because Wyoming has sufficient substitute procedural safeguards to protect indigent obligors against the possibility of wrongful incarceration. View "State, Dep't of Family Servs. v. Currier" on Justia Law

Appellant was injured in a work-related accident in 1996. In 2009, Appellant was diagnosed with a labral tear in his left shoulder. The Workers' Safety and Compensation Division denied Appellant's request for payments for the treatment of the labral tear, determining that the current condition of Appellant's left shoulder was not due to the 1996 work-related accident. The Office of Administrative Hearings affirmed the denial. The district court affirmed. The Supreme Court affirmed, holding that the Division's decision that the injury was not causally connected to a work-related accident was supported by substantial evidence. View "Hampton v. State ex rel. Workers' Safety & Comp. Div." on Justia Law

Defendant entered guilty pleas to aggravated burglary, first-degree murder, and conspiracy to commit aggravated burglary. Defendant was sentenced to life imprisonment on the first-degree murder conviction. At the time of the murder, Defendant was a juvenile. The Supreme Court affirmed, holding that Defendant's sentence of life imprisonment for first-degree murder, mandated by Wyo. Stat. 6-2-101(b), was constitutional. After that decision, the U.S. Supreme Court issued Miller v. Alabama, where it held that the Eighth Amendment forbids a sentencing scheme that mandates life in prison without the possibility of parole for juvenile offenders. Based on Miller, Bear Cloud petitioned for certiorari to the U.S. Supreme Court. The U.S. Supreme Court granted the petition, vacated the judgment in Bear Cloud I and remanded the case to the Wyoming Supreme Court. On remand, the Court held that, in light of the Miller decision, Bear Cloud's sentence for his first-degree murder conviction violated the Eighth Amendment and related U.S. Supreme Court case law. Remanded with instructions to resentence Bear Cloud on the first-degree murder conviction. View "Bear Cloud v. State" on Justia Law

After RB, a middle-aged man, was emergently detained as a suicide risk at West Park Hospital, the district court involuntarily hospitalized RB at the Wyoming State Hospital, where he was detoxified of opiates and other controlled substances and eventually stabilized on psychotropic medications. The State Hospital then notified the district court and the county attorney that it intended to discharge RB. The county attorney filed an objection with the district court, claiming a right to a hearing on the merits of the State Hospital's decision. The district court concluded that the county had no standing to object to RB's discharge. The Supreme Court affirmed, holding that the involuntary hospitalization statutes do not provide authority for a county attorney to object to the proposed discharge of a patient from involuntary civil commitment. View "State v. Wyo. State Hosp." on Justia Law

Plaintiff, the secretary of state, filed a declaratory judgment action challenging the constitutionality of Wyoming's term limit statute. Plaintiff contended that the statute was prevented from exercising his constitutional right to seek a third term as secretary of state. The State retorted that Plaintiff's complaint did not present a justiciable controversy and, in any event, the statute was constitutional. The Supreme Court accepted certification of the issues from the district court and held (1) Plaintiff's complaint satisfied the four elements necessary to establish a justiciable controversy; and (2) the statute limiting the term limit for statewide elected officials is unconstitutional with respect to the offices of secretary of state, auditor, treasurer, and superintendent of public instruction, and the qualifications for those offices provided by the Wyoming Constitution are exclusive. View "Maxfield v. State" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to obtain property by false pretenses and was sentenced to a prison term of eight to ten years. Defendant appealed, challenging the admission of uncharged misconduct evidence and alleging prosecutorial misconduct in the State's sentencing recommendation. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in determining that the probative value of the uncharged misconduct evidence was not outweighed by its potential for unfair prejudice and thus in admitting the evidence; and (2) the State did not commit prosecutorial misconduct in its sentencing memorandum to the district court, and thus the district court entered a sentence permitted by law. View "Magnus v. State" on Justia Law