Justia Wyoming Supreme Court Opinion Summaries

Steve Glen filed suit against his employer, Union Pacific Railroad, claiming that a work-related injury was caused by Union Pacific's negligence. Previously, the Supreme Court reversed a grant of summary judgment in favor of Union Pacific after finding the railroad had a duty to exercise ordinary and reasonable care in the operation of its railway. After remand, the jury determined that both parties, as well as two non-party actors, were negligent and awarded damages to Glenn. The Supreme Court reversed the district court, holding that the district court erred in refusing to admit evidence of a prior incident involving Union Pacific that was the catalyst for a change in the railway's safety procedures and that the error was prejudicial to Glenn. Remanded for a new trial. View "Glenn v. Union Pac. R.R. Co." on Justia Law

Burt Purcella established a trust into which he transferred his assets, including fifty percent ownership in a business. Purcella named his wife and children as successor trustees. Upon Purcella's death, the successor trustees were to divide the remaining trust assets between two trusts, the family trust and the marital trust. After Purcella's death, Children filed an action against Wife, claiming she breached her fiduciary obligations as trustee by depositing funds the marital trust received from the business into her personal account. The district court entered summary judgment enjoining Wife from depositing the funds into her personal account and finding the parties had agreed that 87.05% of all income received from the business would be allocated to the marital trust and distributed to Wife. The Supreme Court reversed the district court's ruling that Wife was entitled to all income the marital trust received from the business, holding that Wife was entitled to payment of income the marital trust received from the business less any expenses incurred in administering the marital trust. View "Purcella v. Purcella" on Justia Law

Appellants were the personal representatives of the estates of a husband and wife who were killed in a car accident. The accident was caused by a driver who, prior to the accident, had become intoxicated as a result of consuming alcoholic beverages at a bar and a saloon in Wyoming. Appellants filed a wrongful death and negligence complaint against the owners of the bar and saloon. Appellants also sought a judgment declaring Wyo. Stat. 12-8-301, which provides that no person who legally provides alcohol to another person is liable for damages caused by the intoxication of the other person, was unconstitutional if, as a matter of law, the statute provided immunity to Appellees for their conduct. The district court granted Appellees' motion to dismiss on the ground that the Supreme Court had already found the statute to be constitutional. The Supreme Court affirmed, holding that (1) in the statute, the word "legally" in the phrase "legally provided" does not encompass municipal ordinances, and (2) the statute violates neither the constitutional doctrine of equal protection nor the constitutional prohibition of special laws. View "Baessler v. Freier" on Justia Law

Myra Jean Ford was convicted of seven counts of forgery. On appeal, Ford contended that the district court abused its discretion when it denied her motion for judgment of acquittal at the close of the State's presentation of evidence, arguing that the evidence the State produced was not sufficient to prove any of the fundamental elements of the crime of forgery. The Supreme Court reversed the district court's judgment and sentence, holding that the district court abused its discretion in denying Ford's motion for judgment of acquittal because the evidence was insufficient to prove beyond a reasonable doubt that Ford acted with the intent to defraud. Remanded with directions that the information be dismissed with prejudice. View "Ford v. State" on Justia Law

David Baker was convicted on six methamphetamine-related charges. The Supreme Court reversed his convictions on two of the charges and affimed the other four. In these consolidated appeals, Baker (1) challenged the district court's denial of his motion to correct an illegal sentence, and (2) claimed the district court erred when it did not grant him access to e-mail correspondence between the department of corrections and the public defender's office. The Supreme Court affirmed the district court's decisions, holding (1) the district court did not abuse its discretion in denying Baker's motion to correct an illegal sentence, and (2) the district court was correct in observing that Baker's motion for subpoena duces tecum asking for the requested e-mail correspondence was not appropriate in the context of Baker's criminal matter. View "Baker v. State" on Justia Law

The Rageths filed suit against the Sidon Irrigation District seeking a declaration of their conveyance rights in the Sidon Canal, reimbursement of water delivery fees paid to the District for past irrigation seasons, and the establishment of a reasonable annual water delivery fee in future years. The parties executed a stipulation that the Rageths have a perpetual right, as defined by their adjudicated water rights, to divert water from the District's diversion structure and convey such water through the Sidon Canal to their property, subject to an annual payment to the District. The district court granted summary judgment in favor of the District on the Rageths' remaining claims. At issue on appeal was, in the absence of an agreement, what water delivery fee may an irrigation district charge a non-member who has a perpetual right to convey that non-member's adjudicated appropriation to that non-member's land outside the irrigation district's boundaries using the irrigation district's canal and related facilities. The Supreme Court reversed the district court, finding that genuine issues of material fact existed and holding that the Rageths' proportionate share of the requisite expenses must be based on an equitable apportionment determined after consideration of the various relevant factors. Remanded. View "Rageth v. Sidon Irrigation Dist." on Justia Law

Employee injured his knee while climbing into his employer-provided truck as he was preparing to leave on a work-related trip. The Wyoming Workers' Safety and Compensation Division (Division) denied Employee's requested workers' compensation benefits related to his injury. The Office of Administrative Hearings (OAH) granted summary judgment in favor of the Division. The district court affirmed the OAH's decision. At issue on appeal was whether Employee's injury was sustained while he was being transported by a vehicle of the employer as the statute requires. The Supreme Court affirmed, holding (1) the statute plainly and unambiguously requires that for an injury sustained during travel to be compensable, it must occur as the employer's vehicle is carrying the employee from one place to another; and (2) because Employee here was entering the vehicle in preparation for that transportation when he was injured, the injury he sustained was not compensable. View "Barlow v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Father was ordered to pay child support and soon developed child support arrearages. Later, Father became disabled. Father and his children received lump sum Social Security disability benefits payments for the period retroactive to the date Father became eligible for the benefits. In a series of orders, the district court gave Father credit (1) against his child support arrearages back to the date he became eligible for benefits, and (2) for amounts that had been withheld from his monthly disability payments under an income withholding order for the period after he became disabled but before he became eligible to receive benefits. The court, however, refused to credit any of the disability payments against arrearages existing on the date Father became disabled. The Supreme Court affirmed, holding that the district court may not credit Social Security disability benefits paid to dependent children against child support arrearage owed before the obligor became disabled. Because such benefits belong to the children, not the obligor, they are not available to be applied as a credit or offset to amounts owed by the obligor. View "Swaney v. State" on Justia Law

In this termination of parental rights case, police officers found illegal drugs and drug paraphernalia in the room where Mother's two children watched television. The Department of Family Services (DFS) removed the children, placed them in foster care, and agreed on a family service plan with Mother. Mother failed to follow the requirements of her service plan. The district court subsequently terminated Mother's rights to the two children. The Supreme Court affirmed, holding that DFS proved, by clear and convincing evidence, (1) Mother was unfit to have custody and control of the children, (2) the children's health and safety would be seriously jeopardized if they returned to Mother, and (3) DFS made reasonable efforts to rehabilitate the family as required by law. View "In re A.R.C." on Justia Law

Carol Middlemass suffered a broken right shoulder in 1987 as a result of a car accident. Middlemass recovered and was able to use her shoulder normally. In 2009, Middlemass stated that she injured her right shoulder while working for Y-Tex Corporation. The Wyoming Workers' Safety and Compensation Division denied Middlemass's request for worker's compensation benefits for the injury due to her preexisting condition. The Office of Administrative Hearings (OAH) upheld the Division's denial, and the district court affirmed. On appeal, the Supreme Court affirmed, holding (1) the OAH hearing examiner's conclusion that Middlemass did not meet her burden of proving that her shoulder injury was caused by her work activities was supported by substantial evidence; and (2) the OAH hearing examiner properly ruled that expert medical testimony was required to establish that Middlemass' work activities caused the injury. View "Middlemass v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law