Justia Wyoming Supreme Court Opinion Summaries

A jury convicted Vincent Scott of first degree sexual assault, aggravated assault, and child abuse. Scott appealed, claiming the district court denied his Sixth Amendment right to represent himself at trial and imposed an illegal sentence. The Supreme Court affirmed, holding (1) the district court in this case had the discretion to deny Scott's untimely request to proceed without counsel, and although it erred in denying the request on the grounds that Scott's decision was not knowing and intelligent, the request was properly denied as untimely; and (2) the sentence imposed was not impossible or illegal because the district court awarded credit for time served, which made the sentencing scheme possible. View "Scott v. State" on Justia Law

A Wyoming Highway Patrol Trooper stopped Bryan Phelps and Justin Fitch for a traffic violation, detained them, conducted a drug dog sniff of their vehicle and, after the dog alerted to the presence of controlled substances, searched the vehicle and found marijuana. Phelps and Fitch were each charged with three felonies. They moved to suppress the evidence seized during the search, and the district court denied the motion. Phelps and Fitch subsequently entered pleas of guilty to one of the counts while reserving their right to appeal the denial of their suppression motion. The Supreme Court affirmed the denial of the suppression motion, holding that there was sufficient evidence to support the conclusion that probable cause existed for the search. View "Phelps v. State" on Justia Law

After a jury trial, Appellant Charles Jones was convicted of aggravated robbery and first-degree murder. Jones appealed, arguing that the trial judge erroneously instructed the jury, that there was insufficient evidence to convict him, and that the prosecutor committed cumulative error. The Supreme Court affirmed, holding (1) the trial judge's failure to give an intent instruction was harmless, as there was no prejudice to Jones; (2) the jury had sufficient evidence to convict Jones of robbery; and (3) Jones was not denied his right to a fair trial due to the cumulative effect of any alleged prosecutorial misconduct that may have occurred. View "Jones v. State" on Justia Law

Black Diamond Energy Partners (BDE Partners) were Nevada limited partnerships which owned interests in coal bed methane wells located in Wyoming. Black Diamond Energy, Inc. (BDE Inc.) was a Wyoming corporation and the managing general partner of several of the BDE Partners. Black Diamond Energy, Inc. of Delaware (BDE Del) was a Delaware corporation and the managing general partner of two of the BDE Partners. BDE Inc. and BDE Del were wholly owned subsidiaries of Koval Resources, LLC, a Nevada limited liability company. Koval entered in a loan agreement in Pennsylvania with S&T Bank, a regional state bank with offices only in Pennsylvania. Koval ultimately defaulted on the loan. BDE Partners filed a complaint in Wyoming against S&T alleging negligence, breach of fiduciary duty, breach of the implied covenant of good faith and fair dealing, and other claims. The district court dismissed the complaint for lack of personal jurisdiction. The Supreme Court reversed, holding that BDE Partners presented sufficient undisputed evidence that S&T's activities in Wyoming were such that, as a matter of law, Wyoming courts had personal jurisdiction to decide their claims. View "Black Diamond Energy Partners Ltd. v. S&T Bank" on Justia Law

After entering a conditional plea to one count of felony child abuse, Roman Vance reserved his right to challenge the denial of his motion to dismiss, which was premised on grounds of constitutional speedy trial. On appeal, Vance claimed that a six and one-half year delay between charging and arrest raised a presumption of prejudice that the State did not persuasively rebut. The Supreme Court agreed and reversed, holding that the district court erred in denying Vance's motion to dismiss based upon a violation of his constitutional speedy trial right, as the court overlooked the question of presumptive prejudice and because no evidence was offered by the prosecution to rebut the presumption of prejudice afforded to Vance. View "Vance v. State" on Justia Law

Appellant in this case attempted to challenge an agency decision denying her claim for unemployment benefits. Appellant filed a timely petition for review of agency action pursuant to Wyo. R. App. P. 12 (Rule 12). The district court dismissed the petition due to procedural deficiencies. Appellant subsequently filed a motion for reconsideration based on Wyo. R. Civ. P. 60 (Rule 60). The district court denied the motion. Appellant then appealed the order denying her motion for reconsideration. At issue on appeal was whether, when a district court enters a final judgment in a Rule 12 agency appeal, a party can file a Rule 60 motion to set aside the court's judgment. The Supreme Court dismissed Appellant's appeal, holding that a Rule 60 motion is not an avenue available to mount a challenge to a district court's final decision in an agency appeal. View "Nicholson v. Dep't of Employment" on Justia Law

Bill Kuhl brought wrongful termination claims against his former employer, Wells Fargo Bank, asserting claims for breach of an express contract of employment, breach of an implied contract of employment, promissory estoppel, and tortious breach of the implied covenant of good faith and fair dealing. After the parties engaged in discovery, Wells Fargo moved for summary judgment. Kuhl resisted that motion. After a hearing, the district court granted summary judgment in favor of Wells Fargo. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of Wells Fargo on any of Kuhl's claims. View "Kuhl v. Wells Fargo Bank, N.A" on Justia Law

Jackman Construction, Inc. was awarded a contract to improve the Town of Baggs' water treatment plant. After the project suffered significant delays, payments were submitted and accepted, and a dispute ensued as to whether or not the last payment constituted "final payment." Jackman filed a governmental claim as well as a complaint for breach of contract, seeking damages from the Town. The Town filed a motion for summary judgment, which the district court granted. The Supreme Court affirmed, holding that under the clear and unambiguous terms of the contract, Jackman agreed to waive all claims by accepting "final payment," which it did. View "Jackman Constr., Inc. v. Town of Baggs " on Justia Law

KM Upstream, LLC and Newpoint, Inc. entered into a contract whereby Newport would construct for KM's amine plant. Newpoint subcontracted with Elkorn Construction, Inc. to build the foundation and perform other work. Elkhorn subsequently filed a lien statement with the county clerk. Elkhorn later filed a complaint against KM for, inter alia, foreclosure of the lien as a mechanic's lien. Newpoint was later added as a defendant. The district court granted summary judgment to Elkhorn to allow foreclosure on the mechanic's lien. The Supreme Court (1) affirmed the grant of summary judgment; but (2) reversed and remanded the district court's determination that $181,369 of Elkhorn's lien claim was disputed and its subsequent order subtracting that amount from Elkhorn's judgment. View "KM Upstream, LLC v. Elkhorn Constr., Inc." on Justia Law

This was an appeal from a forfeiture order entered by the district court against a total of $116,584 and certain items of personal property. The cash and personal property were seized from several individuals because of their alleged use in violation of the Wyoming Controlled Substances Act. Appellants Joseph Libretti and Frank Hohlios claimed $7,209 of the cash seized and appealed the forfeiture order, contending that the district court erred in holding an evidentiary hearing without ruling on their motions to dismiss or for a more definite statement, and in denying them the opportunity to file answers, conduct discovery, file summary judgment motions, or avail themselves of the right to a jury trial. The Supreme Court affirmed, holding that the district court acted in accordance with the Wyoming Rules of Civil Procedure in ruling on the State's forfeiture complaint and did not deny the rights of Appellants to file answers, conduct discovery, file summary judgment motions, or otherwise fully participate in the proceedings. View "Libretti v. State" on Justia Law