Justia Wyoming Supreme Court Opinion Summaries

Appellant Jeramie Large was charged with six crimes arising from an incident when he stole and crashed a vehicle. Large appealed, claiming (1) his right to a speedy trial was violated and (2) he was denied his right to counsel without being adequately instructed and warned of the dangers of proceeding without counsel. The Supreme Court affirmed, holding (1) Appellant was afforded a speedy trial as it occurred without the 180-day time period required by Wyo. R. Crim. P. 48, and any delays did not violate Appellant's Sixth Amendment right to a speedy trial; and (2) Appellant's right to counsel was not violated as the district court adequately instructed Appellant on the dangers of proceeding without counsel. View "Large v. State" on Justia Law

Appellant Danny Rodgers was convicted of check fraud, driving while intoxicated, felony identity theft, and two counts of forgery. Rodgers appealed, raising, among other claims, claims of evidentiary insufficiency and a speedy trial violation. The Supreme Court (1) reversed Rodgers' check fraud conviction, holding that there was insufficient evidence to support the conviction under Wyoming law; (2) reversed Rodgers' felony identity theft conviction because the facts did not support the felony conviction as defined by Wyo. Stat. Ann. 6-3-901(c), and ordered entry of a misdemeanor identity theft conviction because the jury's verdict supported Rodgers' conviction for that lesser-included offense; and (3) held that Rodgers' right to a speedy trial under Wyo. R. Crim. P. 48(b) was not violated under the facts of this case. Remanded for resentencing on the conviction of misdemeanor identity theft. View "Rodgers v. State" on Justia Law

Decedent executed a pour-over will and a revocable inter vivos trust for the intended purpose of disinheriting her surviving Spouse, and thereby effectively destroying his elective share as to the property transferred to the trust. This appeal involved two consolidated cases. The district court granted summary judgment against Spouse in both matters, concluding (1) in the probate matter, the property transferred and held in the trust was not subject to the elective share; and (2) in the related civil action in which Spouse sought $125,000 from the trust as a creditor for work performed during the marriage on a building owned by Decedent and transferred to the trust, the claim was time barred. The Supreme Court affirmed, holding (1) the district court properly granted summary judgment in the probate matter because the property transferred to the Trust was never legally the property of Decedent's estate, and therefore, there was no legal basis for making the property a part of Decedent's estate for purposes of the elective share; and (2) the district court properly found that the failure of Spouse to file his civil complaint against the Estate deprived the court of jurisdiction. View "In re Estate of George" on Justia Law

Appellant Mark Garner was convicted on two counts of delivery of a controlled substance after he was arrested for selling methamphetamine to a confidential informant in two controlled buy operations initiated by the Wyoming Division of Criminal Investigation. Garner appealed, contending (1) the district court improperly limited cross-examination of the confidential informant, a key prosecution witness; and (2) the evidence was insufficient to support his convictions. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in admonishing defense counsel, limiting his cross-examination, and issuing a limiting instruction to the jury when defense counsel was cross-examining the confidential informant; and (2) there was ample evidence to support Appellant's convictions. View "Garner v. State" on Justia Law

Ralph and Wayne Platt were two brothers who, together with their siblings, inherited a ranch. Ralph and Wayne jointly owned and operated one half of the ranch, which they placed in the Platt Ranch Trust. After a dispute, Ralph and some siblings (Appellants) filed suit against Wayne and other siblings (Appellees), asserting a breach of trustee's duties and seeking a partition of the ranch. The district court found that Appellants were entitled to part of the estate and appointed three commissioners to make a partition of the property. The district court affirmed the partition of the estate as recommended by the commissioners with two exceptions. Appellants subsequently filed a motion to alter or amend judgment and/or motion for new partition, arguing that the district court did not have the authority to modify the partition recommended by the commissioners. The court denied the motion. The Supreme Court affirmed, holding that under the circumstances of this case, the district court was authorized as a matter of law to unilaterally modify the partition made by the commissioners in order to obviate the parties' objections to the report. View "Platt v. Platt" on Justia Law

Appellant Steven DeLoge, an inmate in the state penitentiary, was working in the kitchen when he was injured in an altercation with another inmate. Appellant filed a workers' compensation claim based on the injuries sustained from a head-butt from the other inmate. The Wyoming Workers' Safety and Compensation Division (Division) denied the claim. The Office of Administrative Hearings (OAH) concluded that Appellant's injuries were the result of illegal activity and were therefore not compensable under the Wyoming Worker's Compensation Act. The district court affirmed. The Supreme Court affirmed, holding that because the head-butt was a battery under the criminal statute then existing, and therefore an illegal activity, Appellant was not eligible for workers' compensation benefits. View "DeLoge v. State ex rel. Workers' Safety & Comp. Div." on Justia Law

Marvin Tilley was convicted of six counts of sexual assault committed years previously against four different victims and one count of aggravated burglary against one of the victims. Tilley appealed, challenging the sufficiency of the evidence to convict him. At issue on appeal was the credibility of the witnesses and their memories. The Supreme Court affirmed, holding (1) the evidence was sufficient as to the date of the assaults and the fact that the victims did not consent to the sexual acts, (2) there was no basis to question the credibility determinations of the jury, and (3) therefore, the evidence was sufficient to support Tilley's convictions. View "Tilley v. State" on Justia Law

John Eckdahl was sentenced following his conviction of possession of a controlled substance with intent to deliver. Just over a year later, Eckdahl filed a motion to modify his sentence. The district court denied the motion as untimely pursuant to Wyo. R. Crim. P. 35(b), which allows a motion for sentence modification within one year after the sentence is imposed. Eckdahl did not appeal the denial of his motion but instead filed a petition for reconsideration, followed by another motion to reduce his sentence. The district court entered an order denying both the petition for reconsideration and the pending motion for sentence reduction. The Supreme Court dismissed Eckdahl's appeal, holding that it lacked jurisdiction because Eckdahl's motions for sentence reduction were untimely and Eckdahl's petitions for reconsideration were not authorized under Wyoming law. View "Eckdahl v. State" on Justia Law

In these consolidated appeals, Appellant Ryan Hagerman challenged the district court's denials of motions to correct illegal sentence that he filed in two unrelated, but temporally overlapping, cases. Appellant was first sentenced in a burglary case and later sentenced in a stolen property case. The Supreme Court remanded the burglary case for resentencing and affirmed the judgment of the district court in the stolen property case, holding (1) the sentence in the burglary case was illegal because Appellant's presentence confinement time was not properly credited against the sentence; and (2) the sentence in the stolen property case was not rendered illegal by the fact that Appellant was given credit against that sentence to which he was not entitled. View "Hagerman v. State" on Justia Law

Appellants, Timothy Araguz and James Elder, were injured in separate incidents while working at the Wal-Mart Distribution Center. After receiving compensation through Wal-Mart's private workers' compensation fund, Appellants filed for benefits under the Wyoming Worker's Compensation Act. The Wyoming Workers' Safety and Compensation Division denied their request, and the Office of Administrative Hearings confirmed the denial. At issue on appeal was whether Appellants were engaged in extrahazardous employment as defined by Wyo. Stat. Ann. 27-14-108. The Supreme Court affirmed the denial of benefits, holding that Wal-Mart was not engaged in extrahazardous employment as defined by the legislature and, therefore, Appellants were not entitled to workers' compensation benefits. View "Araguz v. State ex rel. Workers' Safety & Comp. Div." on Justia Law