Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court granting Wife's motion filed under Wyo. R. Civ. P. 60 seeking to set aside a stipulated final decree of divorce due to inadvertence or mistake, holding that the stipulated decree was ambiguous, and the record was insufficient to support the district court's interpretation.After the stipulated decree was entered in this case Husband refinanced the marital home. Wife believed she was entitled to half of the net equity in the home at the completion of the refinance, but Husband argued that she was only entitled to half the net proceeds if the house was sold. The district court granted Wife's Rule 60 motion determining that the stipulated decree unambiguously required Husband to pay Wife half the equity in the property from the refinance or sale of the home. The court entered an order requiring that any equity recognized through sale or refinance of the home was to be equally divided between the two parties. The Supreme Court reversed and remanded the case, holding (1) the stipulated decree was ambiguous as to whether Husband was required to provide Wife half the net proceeds in the event of refinance; and (2) the record did not contain sufficient evidence to clarify the stipulated decree under Rule 60(a). View "Van Vlack v. Van Vlack" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion in his criminal case for the return of property seized by law enforcement during the underlying criminal investigation, holding that remand was required.Defendant pleaded guilty to aggravated assault and battery. Several months after he was sentenced Defendant filed a motion requesting suppression of items used as evidence in his case. The district court ruled that it did not have jurisdiction over Defendant's motion in the criminal case because a post-conviction motion for return of property is a civil matter. The Supreme Court reversed, holding that the district court erred in declaring that it did not have jurisdiction to consider Defendant's motion for return of his property, nor did it have the legal authority to order return of the property because the motion was authorized by Wyo. R. Crim. P. 41(d), and the court should have received evidence to determine whether Defendant was entitled to return of the property. View "Bunten v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence, holding that the district court did not err in ruling that res judicata barred Defendant's motion to correct an illegal sentence.Defendant was convicted of second-degree abuse of a minor and soliciting a minor to engage in sexual relations and sentenced to twenty years as to the sexual abuse conviction and to four to five years on the solicitation conviction, to be served consecutively. Defendant later filed a pro se motion to correct an illegal sentence, arguing that the acts underlying his conviction were one continuous act and that his consecutive sentences violated double jeopardy protections. The district court denied relief ruling that res judicata barred the motion. The Supreme Court affirmed, holding (1) a motion to correct an illegal sentence can be subject to res judicata; and (2) the interests of res judictata in finality and avoiding repetitive litigation were served in this case. View "Peterson v. State" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of the State in this action brought by Plaintiffs claiming that a contract health care provider for the State at the Wyoming Medium Correctional Institution (prison) acted negligently when she injected Appellants with the Janssen COVID-19 vaccine, holding that the State was immune from suit and liability.Plaintiffs, inmates at the prison, brought this action claiming that they were wrongfully injected with the Janssen COVID-19 vaccine because the consent forms Plaintiffs signed mentioned only the Moderna and Pfizer COVID-19 vaccines. The district court declined to allow Appellants additional time for limited discovery and granted summary judgment in favor of the State, finding that State had immunity. The Supreme Court affirmed, holding (1) the district court did not err when it declined to allow Plaintiffs limited discovery; and (2) the federal Public Readiness and Emergency Preparedness Act shielded the State from suit and liability in this case. View "Bird v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment for Defendants and denying relief in this class action, holding that the district court did not err.In 2014, over two-thirds of the members of the Try County Telephone Association, Inc., a Wyoming cooperative utility providing telecommunication services on a non-profit basis, voted to sell the Cooperative, including its for-profit subsidiaries, to entities owned by Neil Schlenker. Schlenker converted the Cooperative into a for-profit corporation (TCT). After the sale, Class Representatives filed a class action lawsuit against TCT, Schlenker and his entities, and others, alleging fraud conversion and other claims and requesting that the sale be set aside. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding that the district court did nor err in granting summary judgment on all claims. View "Campbell v. Davidson" on Justia Law

The Supreme Court reversed in part and affirmed in part the judgment of the district court in favor of Baldwin, Crocker & Rudd, P.C. and Kelly Rudd (collectively, BCR) in this action brought by the Northern Arapaho Tribe and the Wind River Hotel & Casino (collectively, the Tribe), holding that the district court's order imposing sanctions on the Tribe was erroneous.The Tribe brought this action seeking injunctions for the return of tribal funds and documents, an accounting, and damages for conversion and civil theft. The district court granted summary judgment for BCR on the accounting and injunctions claims and, after a jury trial, entered final judgment on the conversion and civil theft claim. The Tribe appealed, arguing, among other things, that the district court erred by awarding sanctions under Wyo. R. Civ. P. 11. The Supreme Court reversed in part, holding that (1) the district court erred in imposing sanctions because BCR failed to comply with the procedural requirements of Rule 11; (2) the district court did not err when it granted summary judgment for BCR on the Tribe's accounting claim; and (3) the Tribe failed to show the verdict would have been more favorable if racially charged evidence had not been admitted. View "Northern Arapaho Tribe v. Baldwin, Crocker & Rudd, P.C." on Justia Law

The Supreme Court affirmed the decision of the district court denying Appellant's motion to correct an illegal sentence, holding that the district court correctly concluded that Appellant was not entitled to credit for time spent on probation when he was resentenced in a probation revocation proceeding.Defendant admitted to the State's allegations of probation violations, and his probation was revoked and sentence reinstated. Defendant filed a motion to correct an illegal sentence, claiming that he was entitled to credit for time spent on supervised probation, inclusive of inpatient substance abuse treatment and participation in Treatment Court. The district court denied the motion. Defendant subsequently moved both a second and third time to correct an illegal sentence, without success. Defendant appealed the district court order denying his first request to correct an illegal sentence. The Supreme Court affirmed, holding that the district court properly denied the motion. View "Stevenson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for interference with a peace officer, holding that the district court did not violate Defendant's due process rights by conducting a hearing under Asch v. State, 62 P.3d 945 (Wyo. 2003), in Defendant's absence after he refused to attend the hearing.Defendant, who was serving three consecutive life sentences at the Wyoming State Penitentiary, was charged with interference with a peace officer. Before the scheduled trial date, the State moved to require Defendant to be restrained during trial. The district court conducted an Asch hearing without Defendant and decided to impose restraints at trial. Defendant was convicted of one count of felony interference with a peace officer. The Supreme Court affirmed, holding that Defendant waived any right he had to be present at the Asch hearing by knowingly and voluntarily failing to appear at the hearing due to circumstances within his control. View "Castellanos v. State" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of Shelby Hughes and her law firm, Barney & Graham, LLC, (collectively, Defendants) in the underlying legal malpractice lawsuit, holding that the district court did not err.Michael and Charlene Schlegel were in the process of divorcing when Michael died intestate. Because Charlene inherited portions of Michael's estate that she would not have had the divorce been finalized before Michael died Taran Schlegal, Michael's son, sued Defendants for legal malpractice. The district court granted summary judgment for Defendants, finding that no duty was owed to Taran where there was no evidence that Taran was an intended beneficiary of Defendants' services. View "Schlegel v. Barney & Graham, LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Medical Commission to uphold the determination of the Department of Workforce Services, Workers' Compensation Division that Jon Bressler was not entitled to compensation for three physical therapy sessions in connection with his work-related injury to his right arm, holding that there was no error.The Supreme Court affirmed the order upholding the three final determinations of the Division denying Bressler physical therapy benefits, holding that the Commission's conclusion that Bressler's continued physical therapy was not reasonable and necessary medical care for his work-related injury was supported by substantial evidence. View "Bressler v. State, ex rel. Dep't of Workforce Services, Workers' Compensation Division" on Justia Law