Justia Wyoming Supreme Court Opinion Summaries

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

After Appellant was terminated from his employment with Employer, Appellant applied for and was granted unemployment benefits. Employer appealed. After a hearing, a hearing examiner affirmed and found that Appellant was entitled to unemployment benefits. The Unemployment Insurance Commission reversed, finding that Appellant was not entitled to unemployment benefits. The district court affirmed. The Supreme Court affirmed, holding (1) as a matter of law, the Commission acted within its authority when it reviewed and reversed the hearing examiner's decision to grant Appellant unemployment benefits; and (2) the Commission's determination that Appellant was terminated for engaging in misconduct and was thereby not entitled to unemployment benefits was supported by substantial evidence in the record. View "Koch v. Dep't of Employment, Unemployment Ins. Comm'n" on Justia Law

The district court appointed Attorney to represent an indigent parent in a termination of parental rights action filed by the Wyoming Department of Family Services (DFS). State law required DFS to pay for the costs of the action, including the attorney's fee for the indigent parent. After a jury trial, the parent's parental rights were terminated. Several months later, Attorney filed a motion for an order approving payment of his attorney's fees in his representation of the parent. The district court awarded Attorney a fifty percent reduction from the fees sought in the motion. The Supreme Court affirmed the fee reduction, holding that the district court did not abuse its discretion by reducing Attorney's fee application by fifty percent. View "Tolin v. State" on Justia Law

Appellant filed suit against a paragliding company and the company's employees, owners, and agents (collectively, Appellees) after he sustained injuries during a paragliding training clinic conducted by Appellees. At the time of the incident, Appellant was a member of the United States Hang Gliding and Paragliding Association (USHPA). Appellees filed a motion to dismiss, seeking to enforce a forum selection clause contained in an assumption of risk agreement that Appellant had signed as a condition of his membership with USHPA. Based upon the forum selection clause, Appellees contended that California was the appropriate forum for the litigation. The district court granted the motion to dismiss. The Supreme Court reversed, holding that the forum selection clause contained in the agreement between Appellant and USHPA was not enforceable as between the parties to the present litigation, as Appellees were not parties to that contract and did not consent in advance to the jurisdiction of the California courts. Remanded. View "Venard v. Jackson Hole Paragliding, LLC" on Justia Law

After a jury trial, Defendant was convicted of taking a controlled substance into a jail. Defendant appealed, contending (1) the district court erred by seating an unqualified juror; and (2) the court erred in sentencing by not giving him full credit for time spent in presentence incarceration. The Supreme Court affirmed the conviction and sentence, holding that the district court (1) did not err in seating the jury, as the disputed juror was a resident of the relevant county for the required time period preceding the jury selection and return, and therefore, the juror was qualified; and (2) properly credited Defendant for presentence confinement from the time when Defendant's first sentence expired to the time when the court entered sentence on Defendant's drug-related conviction. View "Lake v. State" on Justia Law

Appellant was convicted of felony larceny after taking a pickup truck without the owner's permission. After the verdict was accepted, Appellant moved for a new trial, alleging that jurors or potential jurors overheard conversations between the State's witnesses, and that the information they overheard tainted and prejudiced them. The district court denied the motion, finding that Appellant had waived his right to ask for a new trial by failing to bring the issue to the court's attention during trial. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in denying Appellant's motion for a new trial on the ground that he waived his challenge by failing to raise it during trial; and (2) there was sufficient evidence of Appellant's intent to deprive the owner of the truck of that property as required for a conviction of larceny. View "Pena v. State" on Justia Law