Justia Wyoming Supreme Court Opinion Summaries

Appellant Warren Rathbun was convicted of attempted kidnapping and was sentenced to life in prison. On appeal, the Supreme Court affirmed the conviction and sentence, holding (1) Rathbun's prosecution for attempted kidnapping was not barred by the doctrine of double jeopardy due to his earlier guilty plea to battery because the two crimes each contained elements not contained in the other, and therefore, there was no preclusive effect; (2) the doctrine of res judicata neither barred the refiling of a charge for attempted kidnapping nor a subsequent preliminary hearing on the charge where there was a dismissal of the charge based upon a failure of proof of probable cause at a preliminary hearing; (3) the district court applied the proper penalty range in imposing sentence; and (4) the district court's determination of the penalty range in imposing sentence did not violate Rathbun's right to trial by jury. View "Rathbun v. State" on Justia Law

Christopher Jones pled guilty to a third battery against a household member and was sentenced to a prison term of four or five years. Jones appealed, contending that Wyo. Stat. Ann. 6-2-501(f)(ii), which prescribes the punishment for battery against a household member, was unconstitutionally vague. The Supreme Court affirmed, holding (1) Jones's argument that the statute was ambiguous did not constitute sufficient grounds to invalidate the statute as the mere fact that a statute is ambiguous is not sufficient in itself to violate the constitutional guarantee of due process; (2) the statute was not ambiguous; and (3) because the statute was unambiguous, the rule of lenity did not apply to the case. View "Jones v. State" on Justia Law

After a jury trial, Ronald Jones was convicted of felony larceny. On appeal, Jones argued that (1) the district court did not have subject matter jurisdiction over the State's larceny charge, (2) the trial court improperly instructed the jury as to the elements of larceny, and (3) there was insufficient evidence to support his conviction. The Supreme Court reversed the circuit court, holding that the failure to include the elements of taking and carrying in the jury instructions was plain error, caused material prejudice to Jones, and required reversal. In addition, the Court held that (1) the district court had subject matter jurisdiction over the offense because the charging documents set forth the elements of the alleged crime; and (2) there was sufficient evidence at trial to sustain Jones's conviction. Remanded for a new trial. View "Jones v. State" on Justia Law

After a jury trial, Michael Downing was convicted of unlawful delivery of a controlled substance. Evidence was presented at trial involving an incident wherein a confidential informant (CI), who was working with the state Division of Criminal Investigation (DCI), arranged to purchase morphine pills from Downing. In his appeal, Downing alleged that the district court abused its discretion by denying his pretrial motion seeking discovery of "other buys" in which the CI participated and by excluding at trial evidence of other such buys. The Supreme Court reversed the judgment of conviction, holding that the district court's rulings excluding evidence of the CI's other buys (1) implicated Downing's Sixth Amendment right to confront a witness and (2) were not harmless error beyond a reasonable doubt. Remanded for a new trial. View "Downing v. State" on Justia Law

When Daniel Gallagher, who purchased property west of land owned by J&T Properties, discovered he did not have access to a nearby public road, Gallagher petitioned the Board of County Commissioners for a private road across J&T's property. The county commissioners concluded that Gallagher had no legally enforceable access and certified the case to district court. The district court granted Gallagher a private road across J&T's property. J&T appealed. The Supreme Court affirmed the judgment of the district court, holding (1) the district court correctly interpreted the law as allowing the condemnation of a private road even though it did not connect directly with a public road and properly refused to require Gallagher to join the owners of land over which he already had easements; and (2) the issue of whether the district court erred by denying J&T reimbursement for the costs of securing and presenting the appraisal used in determining its damages was not properly presented to the district court or the Supreme Court, and therefore, the Court refused to consider the issue. View "J&T Properties, L.L.C. v. Gallagher" on Justia Law

Appellant Dawn Schossow injured her back while working as a nurse. Upon returning to work, Appellant requested permanent partial disability (PPD) benefits pursuant to Wyo. Stat. Ann. 27-14-405(h), which governs the availability of PPD benefits and sets out the elements an injured worker must prove to qualify to receive the benefits. Appellant's request was denied. The Office of Administrative Hearings (OAH) upheld the denial of benefits, and the district court affirmed the OAH's decision. On appeal, Appellant contended that the OAH hearing examiner erred as a matter of law in interpreting section 27-14-405(h)(i) and that the hearing examiner's decision was not supported by substantial evidence. The Supreme Court affirmed, holding (1) the hearing examiner properly applied the statute in assessing what wage to use when determining Appellant's PPD eligibility; and (2) the hearing examiner's conclusion that Appellant was capable of earning ninety-five percent of her pre-injury wage, and thus was not eligible for PPD benefits, was supported by substantial evidence. View "Schossow v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Respondent Douglas Juarez was stopped by a state trooper for failing to signal his merge from an entrance ramp onto the right lane of an interstate. A subsequent search of Juarez's vehicle yielded nine pounds of marijuana. As a result, Juarez was charged with possession and possession with intent to deliver. Juarez filed a motion to suppress the search and seizure of the marijuana on the grounds that the initial traffic stop was illegal. The district court granted the motion, holding that Juarez was not required to signal his merge because Wyo. Stat. Ann. 31-5-217 did not require motorists to signal when merging onto an interstate roadway. On review, the Supreme Court affirmed, holding that (1) there is no basis in the statute to conclude that a motorist is absolutely required to signal to enter the interstate in every instance; and (2) the district court did not err in granting the motion to suppress. View "State v. Juarez" on Justia Law

Anthony Smith was involved in an accident that caused extensive damage to his vehicle, which was insured by State Farm. The vehicle was taken to Lewis Auto Body for repairs, after which State Farm determined that the car was a total loss. State Farm requested that Lewis release the vehicle. In response, Lewis requested payment from State Farm amounting to $30,816 for labor and storage. Lewis then asserted a lien against the vehicle in the amount of $30,816, conducted a lien sale, and obtained title to the vehicle. Smith filed a complaint for replevin and conversion. The district court granted summary judgment to Smith, finding Lewis did not file a valid lien and did not provide proper notice of the sale. Lewis then filed a complaint for money judgment against Smith. In response, Smith filed an emergency petition to prohibit the sale or other disposition of the vehicle. The district court consolidated the actions and awarded damages to Lewis in the amount of $20,516, including $15,240 in storage fees. On appeal, the Supreme Court reversed, holding that Lewis was not entitled to accumulate storage charges after the date that a demand was made for the return of the automobile. Remanded. View "Smith v. Lewis Auto Body" on Justia Law

K.C., a juvenile, was adjudged delinquent. As part of her disposition, she was allowed to remain in a home environment and placed on supervised probation. After K.C. violated various terms of her probation, her probation was revoked and her disposition changed to placement at a state girls' school for an indefinite period. K.C. appealed. The Supreme Court affirmed, holding (1) the juvenile court did not abuse its discretion in imposing sanctions because placement at the girls' school fell within the statutorily allowable sanctions applicable to K.C. and, thus, the court was not required to provide a written justification for the placement; (2) the juvenile court's consideration of a statement K.C. made that she would not follow the rules of a residential program did not violate K.C.'s right against self-incrimination because the statement was considered only in the dispositional phase of the delinquency proceedings; and (3) there was no violation of Wyo. R. Crim. P. 11 because the rule does not apply to juvenile delinquency proceedings. View "In re K.C." on Justia Law

George Sonnett, Jr. and Wendy Burgers-Sonnett purchased twenty acres of land and improvements from Elk Ridge Lodge, which Elk Ridge conveyed by warranty deed. The Sonnetts financed part of the purchase price by giving Elk Ridge a promissory note secured by a mortgage on the property. After the Sonnetts defaulted on the note, Elk Ridge filed suit against the Sonnetts seeking judgment and foreclosure on the property, and the Sonnetts filed counterclaims alleging breach of warranty. Both parties filed competing motions for summary judgment. The district court granted summary judgment in favor of Elk Ridge on its foreclosure claim and denied Elk Ridge's request for attorneys' fees. Both parties appealed. The Supreme Court affirmed the district court's decisions in both appeals, holding (1) the district court did not err in granting summary judgment to Elk Ridge and in denying summary judgment to the Sonnetts on their counterclaim of breach of warranty; (2) the record did not support the applicability of the Sonnetts' equitable defenses of equitable estoppel, waiver, or laches; and (3) the district court reasonably concluded that Elk Ridge was not entitled to attorneys' fees. View "Elk Ridge Lodge, Inc. v. Sonnett" on Justia Law