Justia Wyoming Supreme Court Opinion Summaries

Petitioner Bobby Jenkins was charged with misdemeanor animal cruelty after a horse he owned was discovered in dire physical condition. A jury convicted him of the charges. The district court affirmed. Petitioner petitioned the Supreme Court for a writ of review, alleging ineffective assistance of counsel. The Supreme Court affirmed, holding that Petitioner failed to show that he was materially prejudiced by trial counsel's failure to (1) object to testimony and argument regarding the arrest and incarceration of both Petitioner and his brother, (2) object to the prosecutor's improper questioning of a witness about the credibility of another witness, or (3) object to the prosecutor's question relating to allegedly irrelevant testimony about the condition of other horses and Petitioner's speeding ticket. View "Jenkins v. State" on Justia Law

After a bench trial, the district court held Appellant Martin Hultgren in criminal contempt due to his failure to comply with the terms of a dispositional order entered in a juvenile case. Despite the fact that the charge had been amended to allege only three violations, in its written judgment and sentence for criminal contempt of court the district court indicated that it held Hultgren in contempt on six grounds. Hultgren filed an appeal. Subsequently, the district court entered a judgment and sentence nunc pro tunc order amending its earlier criminal contempt order to reflect that it found that Hultgren violated the juvenile court order in three ways, not six. The Supreme Court affirmed, holding that, given the entry of the nunc pro tunc order, the basis for Hultgren's issue on appeal had disappeared. View "Hultgren v. State" on Justia Law

Appellant Thomas Stastny was convicted of sexual abuse of a minor and attempted sexual abuse of a minor. On appeal, Appellant challenged the district court's admission of evidence of a prior conviction, accused the prosecutor of committing misconduct during closing argument, and alleged that these cumulative errors required reversal of his convictions. The Supreme Court affirmed, holding (1) the doctrine of invited error barred Appellant from raising in his appeal issues concerning the admission of evidence of his prior conviction, (2) plain error did not occur as a result of prosecutorial misconduct during closing argument, and (3) as there was no error, the doctrine of cumulative error did not require reversal of Appellant's convictions. View "Stastny v. State" on Justia Law

Craig Winstead pled guilty to three counts of third degree sexual assault, and the district court sentenced him to ten to fifteen years on each count with the sentence on the first count to be served first and the sentences on the second and third counts to be served consecutively to the first sentence and concurrently with each other. Winstead filed a motion to correct on illegal sentence, claiming his sentences should have merged and asking the court to order that he serve his sentences concurrently. The district court denied the motion. The Supreme Court affirmed, holding that Winstead's claim was barred by the doctrine of res judicata because Winstead could have raised the issue during the sentencing hearing, on direct appeal, or when he filed a motion for judgment and sentence nunc pro tunc and failed to do so. View "Winstead v. State" on Justia Law

Appellant Dana Dickey entered a conditional plea to one count of possession of a controlled substance. Dickey reserved the right to appeal the district court's denial of her motion to suppress the methamphetamine found in her purse following a traffic stop, claiming the evidence should have been suppressed as the fruit of a constitutionally infirm detention under the Fourth Amendment. The Supreme Court affirmed, holding that the district court did not err by denying Dickey's motion to suppress where (1) the detention lasted no longer than necessary to effectuate the purpose of the stop, (2) the use of a drug dog during Dickey's lawful detention did not violate any constitutionally protected right, and (3) law enforcement officers had probable cause to search the vehicle. View "Dickey v. State" on Justia Law

Celeste Grynberg and her husband were co-owners of Grynberg Petroleum. Celeste filed a complaint for declaratory relief, breach of contract, unjust enrichment, and conversion against L&R Exploration Venture and numerous individuals and entities having an interest in the venture (collectively L&R), claiming that L&R owed her compensation for services Grynberg Petroleum provided to L&R and that she was entitled to payment of those amounts. The district court granted summary judgment for L&R and dismissed the complaint on the basis of res judicata, finding that Celeste was in privity with parties involved in prior litigation in Colorado and New York and her complaint involved the same subject matter and issues resolved in those proceedings. The Supreme Court affirmed, holding that Celeste was in privity with her husband, who was a party in the New York proceedings, as the assignee of his interest in L&R and with Grynberg Petroleum as the co-owner of the company and was bound by the prior rulings. View "Grynberg v. L&R Exploration Venture" on Justia Law

Appellant Marshall Washington, while working as a confidential informant for the Division of Criminal Investigation (DCI), was charged with and found guilty of possession of a controlled substance. The district court's judgment and sentence incorrectly stated that Appellant pled guilty to the offenses, and the parties entered a stipulated motion to modify the judgment and sentence to correct the inaccuracy. Washington appealed, arguing that (1) the district court improperly denied discovery of the confidential informant agreement (CI agreement) between him and the DCI as well as the DCI's policy manual; and (2) the matter should be reversed inasmuch as the modified judgment and sentence did not fully comply with Wyo. R. Crim. P. 32. The Supreme Court affirmed the conviction, holding that no reversible error was committed by the trial court because (1) Appellant had access to the CI agreement prior to trial and referred to the document at trial, and denial of Appellant's motion to compel discovery of DCI's policy manual was not an abuse of discretion; and (2) the omissions in the modified judgment and sentence were simply clerical errors that would be corrected on remand to the district court. Remanded. View "Washington v. State" on Justia Law

Shannon Cave suffered a work-related injury and was awarded temporary total disability (TTD) benefits during her recovery. After Cave rejected an offer of temporary light duty work from her employer, the Wyoming Workers' Safety and Compensation Division (Division) reduced Cave's TTD benefits to one-third of the previously authorized amount in accordance with Wyo. Stat. Ann. 27-14-404(j). The Office of Administrative Hearings (OAH) upheld the reduction of TTD benefits. The district court reversed the OAH decision. The Supreme Court reversed the district court's order, holding that the OAH decision was supported by substantial evidence and was not contrary to law as the hearing examiner properly determined that the offer of light duty employment tendered to Cave was bona fide, and therefore, the OAH was obligated to reduce Cave's TTD benefits. View "State ex rel. Wyo. Workers' Safety & Comp. Div. v. Cave" on Justia Law

Kelly Shaffer received breast reduction surgery for medical purposes, after which she was hospitalized for a methicillin-resistant stophylococcus aureaus (MRSA) infection. Shaffer's insurer, WINhealth Partners (WIN), refused to pay for the treatment Shaffer received for her MRSA infection on the basis that it arose from treatment to improve appearance. Shaffer subsequently sued WIN, alleging breach of contract and bad faith contract. The trial court granted summary judgment in favor of WIN, concluding that the insurance contract language clearly and unambiguously excluded coverage for Shaffer's breast reduction surgery as well as treatment of complications arising from non-covered services. The Supreme Court reversed, holding that the district court erred in granting summary judgment to WIN because, based on the evidence in the record, the language of the insurance contract unambiguously provided coverage to Shaffer's non-cosmetic breast reduction surgery. Remanded with directions for the district court to enter summary judgment in favor of Shaffer on her claims for treatment of her MRSA infection. View "Shaffer v. WINhealth Partners" on Justia Law

Francis Weber was severely burned by hot mineral water when he lost consciousness in a steam room in Hot Spring State Park. Weber brought a personal injury action against several defendants, including the State. The district court granted summary judgment in favor of the State, concluding that it was immune from suit pursuant to the Wyoming Governmental Claims Act. The Supreme Court reversed, holding that the State's activities in the park fell within the statutory waiver of immunity for operation and maintenance of a public park as (1) overseeing building construction on leased property and delivery of hot mineral water to lessees are part of the State's operation of the park, and (2) under these circumstances, the State's operation and maintenance of the park included overseeing and/or inspecting its lessee's property. Remanded. View "Weber v. State" on Justia Law