Justia Wyoming Supreme Court Opinion Summaries

The Wyoming Workers' Compensation Division denied Rick Bodily benefits for medical expenses related to his micro-lumbar discectomy for a herniated disc in his lower back after determining that Bodily's medical treatment was not related to his compensable work-related back injuries. The Office of Administrative Hearings (OAH) granted the Division's motion for summary judgment against Bodily. The district court affirmed. The Supreme Court reversed OAH's summary judgment, holding (1) genuine issues of material fact about causation of Bodily's disc herniation existed; and (2) the OAH erroneously acted as the trier of fact at the summary judgment stage in this case by weighing all the evidence and making credibility determinations. View "Bodily v. State ex rel. Workers' Safety & Comp. Div." on Justia Law

Appellant Leah Benjamin was convicted of second-degree murder for the shooting death of her estranged husband. On appeal, the Supreme Court affirmed, holding (1) the trial court did not abuse its discretion by denying Appellant's request to remove a juror who was related to one of the State's listed witnesses; (2) the trial court did not err in refusing Appellant's proposed jury instructions; (3) the trial court did not err in denying Appellant's post-trial motion for judgment of acquittal; and (4) Appellant failed to demonstrate that the prosecutor engaged in prejudicial misconduct during the prosecutor's opening statement, voir dire, or the prosecutor's closing argument. View "Benjamin v. State" on Justia Law

After an audit, the Department of Revenue (DOR) determined that Qwest was not entitled to a refund of sales tax. The tax was incorrectly collected from Qwest's customers and remitted to the state because Qwest did not provide data showing the actual amount of tax collected and remitted by month and by country. Qwest subsequently produced to the DOR the actual sales tax information. The State Board of Equalization (SBOE) supplemented the record with the actual data and reversed the DOR's decision. The district court affirmed. At issue on appeal was whether the SBOE erred by considering the newly produced evidence. The Supreme Court (1)affirmed the SBOE's decision that Qwest was entitled to a refund, but concluded the SBOE erred by considering Qwest's evidence, which was not produced to the DOR during the audit; and (2) remanded so the refund amount could be calculated using an estimate procedure and information available during the audit. View "Wyo. Dep't of Revenue v. Qwest Corp." on Justia Law

Appellant Mark Orchard was arrested for driving while under the influence of alcohol. As a result, the Wyoming Department of Transportation (DOT) advised Appellant that it was suspending his driver's license. Appellant contested the suspension before the Office of Administrative Hearings (OAH), and the OAH upheld the suspension. The district court affirmed. Appellant appealed, contending that the police officer who arrested him lacked reasonable suspicion to initiate the traffic stop. The Supreme Court affirmed, holding that the DOT's certified record, which included the arresting officer's signed statement, constituted relevant evidence that a reasonable mind might accept as adequate to support the determination that the arrested office had probable cause or reasonable suspicion to initiate a traffic stop of Appellant's vehicle. View "Orchard v. State Dep't of Transp." on Justia Law

Appellant Joshua Lascano was convicted of one count of burglary and sentenced to six to ten years. During trial, in order to have evidence indicating that Lascano was a member of a gang admitted, the State asserted that the burglary was an act of gang retaliation and that, but for the gang affiliations, the burglary would not have occurred. Lascano appealed, arguing that the prosecutor committed misconduct by misrepresenting the relevance of the gang evidence. The Supreme Court affirmed, holding (1) no prosecutorial misconduct occurred when gang evidence was admitted in this case, and (2) the district court did not abuse its discretion in so admitting the gang evidence. View "Lascano v. State" on Justia Law

A state trooper stopped William Tiernan on suspicion of driving while impaired after he observed Tiernan's vehicle cross the center line and fog line a couple of times. The trooper conducted field sobriety tests and arrested Tiernan for driving under the influence of alcohol. Tiernan refused to submit to chemical testing. The Department of Transportation (DOT) subsequently suspended Tiernan's driver's license. The Office of Administrative Hearings (OAH) upheld the suspension. The district court affirmed. Tiernan appealed, contending that the trooper failed to present sufficient facts to support the stop for a lane violation. The Supreme Court affirmed, holding that substantial evidence supported the agency's decision. View "Tiernan v. State" on Justia Law

Appellant Randal Craft entered a conditional guilty plea to felony possession of a controlled substance and reserved the right to appeal whether he entered a valid waiver of counsel in a prior conviction that was used to enhance the present charge to a felony. The Supreme Court affirmed, holding that the district court did not err in finding Appellant's waiver of counsel in the proceeding at issue was knowing and intelligent where the advisements given in the proceeding complied with the requirements of Wyo. R. Crim. P. 11, and there was no indication in the record that Appellent did not understand those advisements, including the advisement that he had a right to an attorney. View "Craft v. State" on Justia Law

Mother's three children were removed from her custody after they were adjudicated to be neglected. The juvenile court first ruled that the children should temporarily live with their grandparents and father and later ruled that the children should remain with their grandparents and father rather than be returned to Mother's custody. Mother appealed, arguing (1) the juvenile court erred when it ordered, without notice to Mother and without conducting an evidentiary hearing, that her children remain with their grandparents and father; (2) the juvenile court erred by failing to apply Wyo. Stat. Ann. 14-3-405 in deciding the State's motion to change custody and placement of the minor children; and (3) the juvenile court's findings of fact were not supported by clear and convincing evidence. The Supreme Court affirmed, holding (1) the juvenile court did not abuse its discretion by temporarily maintaining the placement of the children with their grandparents and father because Mother was given adequate notice and an opportunity to be heard; (2) the juvenile court's conclusions of law were decided under the correct statute; and (3) the juvenile court did not err in finding that the statutory requirements for out of home placement were met. View "D.R.S. v. Dep't of Family Servs." on Justia Law

In 1999, James Graham was convicted on four counts of obtaining property by false pretenses. Graham's appeal challenged the amount of restitution ordered as part of his sentence. The Supreme Court affirmed in part and reversed in part. In 2010, Graham filed a motion to correct an illegal sentence. The district court ruled that Graham's sentence was not illegal and denied the motion. The Supreme Court affirmed, holding (1) Graham's appeal was barred under the doctrine of res judicata because he could have raised the majority of his issues in his initial appeal and did not suggest any good cause for failing to do so; (2) because res judicata barred his claims that the underlying sentence was illegal, there was no foundation for his challenge to the subsequent revocation of his probation; and (3) the Court was not compelled to consider Graham's claims in the interests of justice, largely because his claims were without merit. View "Graham v. State" on Justia Law

Appellant Christopher Harrell was convicted of rape, kidnapping, and assault. Appellant appealed, arguing that the district court abused its discretion when it did not allow him to introduce evidence that he had been acquitted of a previous battery charge and that his Sixth Amendment right to compulsory process was violated because he was deprived of testimony that was vital, material, and relevant to his defense. The Supreme Court affirmed, holding that Appellant's arguments were not persuasive and that Appellant did not demonstrate that he suffered prejudice from the district court's refusal to allow him to introduce testimony about his previous acquittal for battery. View "Harrell v. State" on Justia Law