Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of failing to notify law enforcement of a change in his residential address, holding that the State presented sufficient evidence at trial to support the conviction.After a jury trial, Defendant was found guilty of two violations of the Sex Offender Registration Act for failing to notify law enforcement of a change in his residential address. Defendant appealed, arguing that there was insufficient evidence presented at trial to support his conviction. The Supreme Court affirmed, holding that the evidence was clearly sufficient to show that Defendant was required and failed to register two residential addresses. View "Martens v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion for sentence reduction, holding that the district court erred in ruling that the motion was untimely but that the error was harmless.After a jury trial, Defendant was found guilty of several crimes, including aggravated burglary. The court sentenced Defendant to a total of twelve to twenty years followed by seven years of probation. The Supreme Court affirmed, holding (1) the district court erred in ruling that Defendant's motion for sentence reduction was untimely, but the error was harmless; and (2) the district court did not abuse its discretion in denying Defendant's motion for sentence reduction. View "Buckingham v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of four counts of sexual abuse of a minor in the first degree soliciting to engage in illicit sexual relations, attempt to commit sexual abuse o a minor in the second degree, and battery, holding that there was no abuse of discretion or cumulative error.Specifically, the Supreme Court held (1) the district court did not abuse its discretion by admitting hearsay evidence in violation of Wyo. R. Evid. 802; (2) the district court did not abuse its discretion by admitting evidence in violation of Wyo. R. Evid. 403; and (3) because there was no error, there was no basis for Defendant's claim that evidentiary errors cumulatively deprived him of a fair trial. View "Munda v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's petition filed under the Post-Conviction Determination of Factual Innocence Act alleging that he was factually innocent of three convictions because the victim recanted her trial testimony, holding that the district court did not clearly err.After he was convicted of five counts of sexual assault and sexual abuse of a minor involving two victims Appellant petitioned the district court asserting that he was factually innocent based on the victim's recantation. After a hearing, the district court found that Appellant did not offer clear and convincing evidence of his innocence and denied the petition on the merits. The Supreme Court affirmed, holding that there was no basis for this Court to disturb the district court's ruling. View "Shawn v. State" on Justia Law

The Supreme Court affirmed Defendant's sentence and the order of the district court denying Defendant's motion for a sentence reduction and correction, holding that there was no error.Defendant was convicted of six counts of aggravated child abuse and sentenced to concurrent prison terms of four to eight years on each count. In his motion for a sentence reduction and correction Defendant argued that his sentence was illegal on several grounds. The district court denied the motion. On appeal, Defendant argued, among other things, that the court failed adequately to consider probation and that his sentence was further illegal on several grounds. The Supreme Court affirmed, holding (1) the record did not support Defendant's claim that the district court failed to consider a sentence of probation; (2) the presentence investigation report's lack of a recommendation on probation did not render Defendant's sentence illegal; and (3) Defendant's sentence was not cruel or unusual. View "Martinson v. State" on Justia Law

The Supreme Court affirmed the decision of the Board of Equalization upholding the final determinations of the Department of Revenue (DOR) increasing the taxable value of Jonah Energy LLC's natural gas liquids (NGL) production for 2014 through 2016, holding that Jonah was not entitled to relief on its allegations of error.On appeal, Jonah argued that the Board misinterpreted the NGL purchase agreement between Jonah and the purchaser of its NGL, Enterprise Products Operating LLC, by refusing to account for deficiency fees Jonah paid to Enterprise in determining the NGL's taxable value. The Supreme Court affirmed, holding (1) the Board did not misinterpret the NGL purchase agreement at issue; and (2) the Board did not err by failing to take the facts and circumstances surrounding execution of the purchase agreement into account when interpreting it because there was no basis for losing outside the four corners of the purchase agreement to determine its meaning. View "Jonah Energy LLC v. Wyo. Dep't of Revenue" on Justia Law

The Supreme Court affirmed the judgment of the district court confirming the arbitration panel's finding that a non-compete clause Dr. Michel Skaf signed in his employment contract with Wyoming Cardiopulmonary Services (WCS) was unenforceable but that a previously-granted liquidation award was still valid, holding that there was no error.After WCS terminated Skaf for cause Skaf opened his own cardiology office. WCS sued Skaf for breaching the non-compete clause in the parties' employment contract. The arbitration found Skaf violated the noncompete clause and awarded WCS liquidated damages. The Supreme Court remanded the case. On remand, the arbitration panel again found in favor of WCS, that the non-compete clause was unenforceable, but that the liquidated damages award was still valid. The district court confirmed the award. The Supreme Court affirmed, holding (1) the panel did not commit manifest error by denying Skaf interest on his deferred compensation award; and (2) because Skaf did not previously appeal the panel's award, he was barred from doing so now. View "Skaf v. Wyo. Cardiopulmonary Services, P.C." on Justia Law

The Supreme Court affirmed the district court's award of $21,643.65 in attorney fees and costs to DAPCPA RPO, a full-service public accounting firm, after the court concluded that Defendant breached a purchase and sale agreement (PSA) and a covenant not to solicit, holding that there was no error.Defendant, a former employee of DAPCPA RPO, formed a new firm and provided services to former DAPCPA RPO clients. DAPCPA RPO filed suit, alleging several claims. The district court granted summary judgment for DAPCPA RPO in part, concluding that the parties' PSA and covenant not to solicit were valid and enforceable contracts and that Defendant breached them. Ultimately, the Court awarded DAPCPA RPO a total of $21,643.65 in attorney fees and costs. The Supreme Court affirmed, holding that the district court did not abuse its discretion in determining that DAPCPA RPO was entitled to its fees and costs. View "Hensel v. DAPCPA RPO LLC" on Justia Law

The Supreme Court affirmed Defendant's convictions of attempted murder, aggravated assault and battery, and other charges arising from a high-speed car purist and shootout with law enforcement officers, holding that the State did not commit prosecutorial misconduct.On appeal, Defendant argued that the State committed prosecutorial misconduct by presenting certain statements and information obtained from psychologists who conducted his competency and mental illness or deficiency evaluations. The Supreme Court disagreed and affirmed, holding that the record disclosed no gross prosecutorial impropriety that deprived Defendant of his right to a fair trial or attempt to persuade the trial court wrongly to convict him. View "Adams v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct illegal sentence, holding that the district court did not err by not awarding sentencing credit for time spent on probation and for time spent in substance abuse treatment as a condition of probation.Defendant pled guilty to felony driving under the influence. The district court suspended Defendant's suspended in favor of probation. The court later revoked Defendant's probation for violations of conditions of probation. Less than one year later, the court again revoked Defendant's probation. Defendant subsequently filed a letter that the district court construed as a motion to correct an illegal sentence, requesting credit for time spent in an inpatient treatment facility. The district court denied the request. The Supreme Court affirmed, holding that, under established precedent, the district court did not err in finding that Defendant was not entitled to credit for the time he participated in his treatment program. View "Hiltner v. State" on Justia Law