Justia Wyoming Supreme Court Opinion Summaries

Joyce Anderson and Jerry Allen were involved in a long-term, non-marital relationship. Upon separation, the parties entered into a settlement agreement stating that each should have ownership of personal property in their respective possession. Allen later claimed some of the items Anderson took were his and filed a motion seeking recovery of those items through enforcement of the terms of the settlement agreement. The district court determined that Allen failed to claim the personal property at issue in a timely fashion and thus effectively abandoned his claim to it. The Supreme Court affirmed the decision that Allen had no claim to the property at issue but did so on separate grounds. The Court concluded that the settlement agreement granted ownership of the real property, including the shed in which the items at issue were located, to Anderson free of any claim or demand of Allen. All personal property on the land therefore was in Anderson's possession and granted to her under the terms of the settlement agreement. View "Allen v. Anderson" on Justia Law

In 2006, Will Torres claimed he injured his low back in a slip-and-fall accident at Home Depot where he worked. Torres had suffered two previous injuries to his low back. In January 2007, Torres received an MRI, which a doctor later used to diagnose Torres with multilevel degenerative disease. In August 2007, Torres had surgery performed on his back. Torres sought worker's compensation benefits from the Wyoming Workers' Safety and Compensation Division related to the back surgery. The division denied Torres disability benefits, determining that the surgery was not causally related to the 2006 accident. The division's denial was upheld by the Office of Administrative Hearings and later by the district court. Torres appealed. The Supreme Court affirmed, holding the hearing examiner's determination that Torres had failed to prove a causal relationship between the fusion surgery and the 2006 work incident was not against the overwhelming weight of the evidence. View "Torres v. State ex rel. Wyoming Workers' Safety and Compensation Division" on Justia Law

Appellant appealed his murder conviction and the denial of his motion for a new trial without a hearing. At issue was whether the district court abused its discretion by failing to grant the appellant's motion for a new trial and whether the prosecutor committed misconduct by violating discovery orders, by violating a pre-trial order regarding uncharged misconduct evidence, and by eliciting testimony from a law enforcement officer that the officer believed a witness was lying during an interview. The court held that, in the context of the overwhelming evidence of appellant's guilt, and the district court's detailed curative instruction, the court could not say that the post-trial motion should have been granted because plaintiff had not met his burden of showing that he was prejudiced by the denial of the new trial motion in respect to the stricken testimony. The court also held that appellant failed to show that the prosecutor committed reversible misconduct and therefore, the court affirmed the judgment and sentence. View "Willoughby v. State" on Justia Law

In an effort to address a perceived drug and alcohol problem among its students, Goshen County School District No. 1 ("school district") adopted a policy requiring all students who participated in extracurricular activities to consent to random testing for alcohol and drugs. At issue was whether the district court properly granted summary judgment in favor of the school district where both parties agreed that there were no genuine issues of material fact but disagreed about whether the district court correctly applied the provisions of the Wyoming and United States Constitutions to the undisputed facts. The court held that appellants failed to demonstrate that the school district's policy subjected students to searches that were unreasonable under all of the circumstances and therefore, the policy did not violate Article 1, section 4 of the Wyoming Constitution. The court also held that the fact that the policy did not subject students to unreasonable seizures was, therefore, determinative of appellants' equal protection claim as well. The court further held that appellant had not demonstrated infringement of due process rights where appellants' speculation that judicial review might be denied in the future was insufficient to support a due process claim now. Accordingly, because appellants failed to prove that the school district's policy was unconstitutional, there was no basis for their claim that they were entitled to a permanent injunction or for their claim that the district court erred in granting summary judgment. View "Hageman v. Goshen County Sch. Dist. No. 1" on Justia Law

Paula Christiansen and Victoria Lee Christiansen, both residents of Wyoming, legally married in Canada in 2008. Paula Christiansen filed an action for divorce in Wyoming in 2010. At issue was whether a Wyoming district court had subject-matter jurisdiction to entertain a divorce action to dissolve a same-sex marriage lawfully performed in Canada. The court held that the district court had subject-matter jurisdiction to entertain the petition for divorce where the court found nothing in Wyoming statutes or policy that closed the doors of the district court to two Wyoming residents seeking a legal remedy to dissolve a legal relationship created under the laws of Canada.View "Christiansen v. Christiansen" on Justia Law

In two consolidated appeals, the Town of Evansville ("town") Police Department ("department") appealed the district court's order of reversal for agency inaction filed July 23, 2009 and the district court's order denying motion for relief from an order filed April 15, 2010. The appeals arose from the department's efforts to terminate the employment of plaintiff, a police officer in the department. The court held that, considering all the facts of record relative to plaintiff's request for appeal of the termination of his employment, including the consent of the attorney for the town for an extension of the ten day deadline to request a hearing, the court found that the requirements of Article 23 of Chapter 2 of the Ordinances of the town was sufficiently invoked to require a post-termination hearing. As a result, the inaction of the department in failing to provide the required hearing before the governing body must be reversed, with the matter remanded to afford the rights prescribed by the town's own ordinance.

Appellant was convicted of two counts of unlawfully touching a household member for a third or subsequent time in the past ten years, in violation of Wyo. Stat. Ann. 6-2-501(b) and (f)(ii). The second incident of abuse to which that count related occurred 15 days after the amendment to the battery statute became effective and the revised subsection (b) no longer included the unlawful touching language as a means of committing battery. At issue was whether the trial court committed reversible error by allowing amendment of the Information after the jury had entered into deliberations, withdrawing a jury instruction from the jury and replacing it with a new instruction, despite appellant's objection. Also at issue was whether the trial court imposed an illegal sentence and committed reversible error. The court concluded that, because of the 15 day lapse from the time the statute was amended to the second of appellant's domestic violence offenses, the State's citations to subsection (b) instead of subsection (g) was a mere oversight. Therefore, the court held that appellant was not prejudiced by the Amended Information because he was not charged with a new crime when the State merely corrected a clerical error. The court also held that the sentence imposed by the trial court was an improper interpretation of the statute where unlawful touching, as it was used in section 6-2-501(g) could only be a misdemeanor subject to penalties in section 6-2-501(h) and therefore, appellant's 2 to 5 year prison sentence was illegal. Accordingly, the court remanded to the district court for resentencing.

Petitioner entered into a contract with respondent for the construction of a hotel. After seventeen months of work on the project, petitioner terminated the contract with respondent and respondent subsequently filed a lien against the hotel property for amounts it claimed remained owing. Petitioner filed a petition to strike the lien pursuant to Wyo. Stat. Ann. 29-1-311(b), which the district court denied on the ground that petitioner failed to prove respondent knew, when it filed its claim of lien, that the lien was groundless or contained a material misstatement or false claim. Petitioner appealed, claiming that the district court improperly placed the burden of proof on petitioner and that the district court's factual findings were clearly erroneous. The court affirmed and held that, although it agreed that the burden of proof under the statute was on the lien claimant, the court found that the district court's ruling was properly based on the evidence presented by the lien claimant, respondent, and on the failure of petitioner to allege proper grounds for relief under the statute.

Appellant was convicted of first-degree sexual assault and first-degree murder and sentenced to life in prison. Appellant, acting pro se, filed an action under 42 U.S.C. 1983 contending that he was denied his constitutional right of access to the courts because he did not have adequate access to Wyoming legal research materials in a Nevada state correctional facility. Appellant challenged the district court's dismissal of his suit based on a failure to state a claim. The court affirmed the judgment and held that the facts set forth in the complaint did not allege an actual injury and without any facts to indicate that appellant could have filed a viable petition for post-conviction relief, it could not determine that he had been injured by the expiration of the applicable statute of limitations. The court also held that, because appellant was able to file at least five petitions seeking relief from his conviction while he was an inmate at the Nevada state prison, and he was represented by court-appointed counsel in at least one of those actions, appellant's ability to conduct this volume of legal activity further indicated that he retained meaning access to the courts.

The City of Torrington ("city") filed suit against Strong Construction, Inc. ("Strong") alleging breach of contract claims based on Strong's failure to supply and install water pump motors that conformed to contract specifications. At issue was whether the district court's judgment in favor of the city was supported by the record. The court affirmed and held that the district court's determination was not clearly erroneous where there was ample evidence to support the district court's decision that the Centripro Guidelines were provided to Baker & Associates, the city's engineer, prior to approval of the project submittals; where Strong breached the agreement with the city by failing to provide motors that conformed to the specifications in the parties' agreement; where section 13.07 of the General Conditions did not preclude the city's breach of contract claim and the repair obligation, by its terms, was not limited to one year; and where the court found no basis in common law to extend apportionment of damages to breach of contract claims and the comparative fault statute was not applicable to the breach of contract action.