Justia Wyoming Supreme Court Opinion Summaries

After being separately cited and arrested for driving while under the influence of alcohol (DWUI), Ricky Miller and Christopher Gonzalez (Petitioners) petitioned the district court for review of agency inaction by the Wyoming Department of Health (WDOH). Miller and Gonzalez requested that the district court require the WDOH to retroactively decertify the chemical test operators who had performed chemical tests of Petitioners' breath to determine the quantity of alcohol in their respective bodies. The district court dismissed the petition on the grounds that Petitioners lacked standing to bring the action and that the matter was not ripe for review. The Supreme Court affirmed, holding that Petitioners did not satisfy the three elements of standing as set forth in Lujan v. Defenders of Wildlife, and therefore, the district court did not err in dismissing Petitioners' petition for review for lack of standing. View "Miller v. Dep't of Health" on Justia Law

Earl and Nawana Wallace (the Senior Wallaces) borrowed $15,789 from Pinnacle Bank - Wyoming to finance a vehicle the Senior Wallaces purchased for their son and his wife (the Junior Wallaces). The collateral for the loan was the vehicle the Senior Wallaces bought for and titled in the Junior Wallaces' names. To that end, the Junior Wallaces signed a third party security agreement pledging the vehicle as collateral. The Junior Wallaces subsequently filed a bankruptcy petition. The bankruptcy trustees eventually sold the vehicle to benefit the bankruptcy estate. The Senior Wallaces thereafter stopped making payments on the loan. Pinnacle then filed a complaint seeking damages in the amount of the principal due on the note. The district court granted Pinnacle's motion for summary judgment. The Supreme Court affirmed, holding that none of the Senior Wallaces' asserted defenses excused them from meeting their loan obligation. View "Wallace v. Pinnacle Bank - Wyo." on Justia Law

Dan Artery was attacked by three Boston terriers that were under the care of Frank Jones and Amy Bates. Artery brought an action against Jones and Bates for injures he sustained during the attack. During trial, Jones admitted one hundred percent liability for the injuries, and the district court dismissed Bates as a defendant. The jury then awarded Artery damages in the amount of $13,059. The district court thereafter ordered Jones to pay Artery's costs. Jones appealed a portion of the awarded costs. The Supreme Court affirmed in part and reversed in part, holding that the district court abused its discretion in awarded costs for witness subpoena service fees for an earlier vacated trial because the original trial date was vacated by the district court on its own motion. Remanded. View "Jones v. Artery" on Justia Law

These consolidated appeals arose from a judgment on jury verdict in a case involving personal injuries suffered by Appellant Marcia Beckwith. Beckwith fell from a horse while on a trail ride operated by the Gros Ventre River Ranch in Grand Teton National Park. The jury found that Beckwith's injuries were the result of an inherent risk of horseback riding as defined by the Wyoming Recreation Safety Act, and she therefore recovered no damages for her injuries. In one appeal, Beckwith claimed the district court erred in failing to instruct the jury as she requested. In the other appeal, Beckwith claimed the district court erred in awarding costs to Appellees, the ranch and the ranch's owners, due to her indigence. The Supreme Court affirmed, holding (1) the district court properly instructed the jury as to Appellant's claims, and also provided an appropriate form of special verdict for the jury's use; and (2) the award of costs the district court made was not an abuse of discretion. View "Beckwith v. Weber" on Justia Law

In 2003, Shaw Construction obtained a line of credit from Rocky Mountain Hardware (RMH). Over the years, RMH supplied hardware for several jobs on which Shaw was the general contractor. In 2007, Shaw began work on a project for Snake River Sporting Club in which it acted as construction manager rather than general contractor. Although RMH was chosen as the hardware supplier, no separate contract was executed between RMH and either Shaw or Snake River. After none of the balance due was paid, RMH filed the instant action against Shaw, claiming Shaw was obligated to pay the outstanding balance and that RMH had a written contract with Shaw by virtue of the 2003 credit agreement. Shaw claimed Snake River was responsible for all payments to suppliers. The district court ordered Shaw to pay for the hardware furnished by RMH on the project as well as contractual interest and attorney fees. The Supreme Court affirmed, holding that the district court properly ruled the credit agreement applied in this case and, pursuant to its terms, Shaw was responsible for the principal balance due on the hardware contract, together with contractual interest and attorney fees. View "Shaw Constr., LLC v. Rocky Mountain Hardware, Inc." on Justia Law

Pursuant to a plea agreement, Christina Clark pled guilty to two counts of third degree sexual abuse of a minor. The district court sentenced her to two concurrent terms of six to ten years in prison. Clark appealed from the judgment and sentence, claiming her guilty pleas were not voluntary and she was entitled to a new sentencing hearing because the district court failed to mention probation in the written judgment and sentence in accordance with Wyo. R. Crim. P. 32. The Supreme Court affirmed but remanded for entry of an amended judgment, holding (1) Clark made a voluntary and informed choice to plead guilty; and (2) the district court in this case clearly considered probation before imposing a prison sentence. Remanded to the district court with directions to enter an amended sentence reflecting that the court considered probation in accordance with Rule 32. View "Clark v. State" on Justia Law

Appellant Chip Dave purchased a car on eBay. Before he took possession of the vehicle, the seller sold it to another buyer, Appellee Bill Valdez. Appellant filed a complaint against Appellee citing a number of causes of action, including replevin. Following Appellee's failure to respond to Appellant's second amended complaint, a default judgment was entered and Appellant was granted a writ of replevin ordering Appellee to relinquish possession of the vehicle. Appellant then appealed the district court's denial of an award of attorney fees, arguing that the American rule, requiring each party to pay his or her own attorney fees, was inapplicable. The Supreme Court affirmed, holding (1) the statutory exception to the American rule applies only where the legislature has made it explicit that attorney fees will be allowed; and (2) in this case, no exception to the American rule applied. View "Dave v. Valdez" on Justia Law

Dennis Poitra and two other assailants were involved in the armed robbery of a residence that ended in the killing of a seventy-six-year-old. A jury convicted Poitra of felony murder, aggravated burglary, and conspiracy to commit burglary. The Supreme Court affirmed, holding (1) the trial court did not err in denying Poitra's right to present the defense of involuntary intoxication and in refusing to instruct the jury on the defense of involuntary intoxication; (2) the trial court did not abuse its discretion in denying Poitra's motion to change venue and did not violate his right to a trial by a fair and impartial jury in doing so; and (3) the district court did not abuse its discretion in sentencing Poitra to life imprisonment without the possibility of parole. View "Poitra v. State " on Justia Law

John and Minerva Sutherland entered into a mining lease granting Meridian Granite Company the right to conduct mining operations on the Sutherlands' property. A dispute developed between the Sutherlands and Meridian regarding the Sutherlands' obligation to pay taxes relating to the mineral production. The dispute led to litigation. The district court granted Meridian's motion for summary judgment, ruling that the Sutherlands were obligated to pay the disputed taxes. The Supreme Court affirmed, holding that the district court did not err in allowing Meridian to deduct ad valorem and severance taxes from payments to the Sutherlands when such tax payments were not required by the State, as the Sutherlands and Meridian agreed in the mining lease that the Sutherlands would pay the taxes. View "Sutherland v. Meridian Granite Co." on Justia Law

Appellant Hailey Remmick was convicted of six counts of receiving stolen property and one count of conspiracy to commit larceny by a bailee. Remmick appealed, claiming that pre-charging delay deprived her of due process of law and that there was insufficient evidence to support the jury's verdict. The Supreme Court affirmed, holding (1) because there was no indication that the delay in bringing charges was motivated by an intentional effort to gain tactical advantage over Remmick or evidence that Remmick suffered any actual prejudice, the district court did not err in denying Remmick's motion to dismiss the charges; and (2) there was sufficient evidence to support Remmick's convictions on the charges of receiving stolen property and conspiracy to commit larceny by a bailee. View "Remmick v. State" on Justia Law