Justia Wyoming Supreme Court Opinion Summaries

In 2020, Wagonhound Land & Livestock, LLC purchased the 14,000-acre Tomahawk Ranch in Converse County, Wyoming. Shortly after, Wagonhound filed an action to quiet title to approximately forty acres that Boot Ranch, LLC had occupied and used since at least 1984. Boot Ranch counterclaimed for adverse possession of the property. The district court found that Boot Ranch had made a prima facie showing of adverse possession but concluded that Wagonhound had rebutted this claim by proving the existence of a fence of convenience and neighborly accommodation, thus quieting title in Wagonhound’s favor.The District Court of Converse County held a four-day bench trial and found that Boot Ranch had continuously used the disputed property for grazing, recreation, hunting, and fishing since at least 1984. However, the court concluded that the fence partially enclosing the property was a fence of convenience and that the use of the property was a result of neighborly accommodation. Consequently, the court ruled that Boot Ranch’s use was permissive, defeating its adverse possession claim. Boot Ranch appealed the decision.The Supreme Court of Wyoming reviewed the case and found that the evidence did not support the district court’s findings that the fence was one of convenience or that the use of the property was a neighborly accommodation. The court noted that there was no evidence of a convenience served by the fence and that the actions of removing trespassing cattle indicated assertions of exclusive ownership rather than permissive use. The Supreme Court of Wyoming reversed the district court’s decision and remanded the case for entry of an order quieting title to the disputed property in favor of Boot Ranch. View "Boot Ranch, LLC v. Wagonhound Land & Livestock Co., LLC" on Justia Law

Jaimen Anthony Scott Aisenbrey pled guilty to two counts of possession of a controlled substance with intent to deliver as part of a plea agreement. The agreement stipulated that the State would not argue against probation if the presentence investigation (PSI) recommended it. The PSI recommended a split sentence, but at sentencing, the State requested incarceration. The district court sentenced Aisenbrey to concurrent terms of eight to ten years in prison. Aisenbrey appealed, claiming the State breached the plea agreement and that his counsel was ineffective for not objecting to the State's recommendation.The District Court of Platte County accepted Aisenbrey's guilty plea and the plea agreement terms. However, at sentencing, the State argued for incarceration despite the PSI's split sentence recommendation. Aisenbrey's counsel did not object to this recommendation. The district court imposed the prison sentence as requested by the State.The Wyoming Supreme Court reviewed the case. The court held that the State did not breach the plea agreement because a split sentence, which includes a period of confinement, is not equivalent to probation, which does not involve confinement. Therefore, the State's recommendation for incarceration did not violate the plea agreement. The court also found that Aisenbrey's counsel was not ineffective for failing to object to the State's recommendation, as there was no breach of the plea agreement to object to. The court affirmed the district court's decision. View "Aisenbrey v. State" on Justia Law

The Wyoming Board of Land Commissioners (Board) manages state trust lands for the benefit of public schools. In Teton County, the Board issued temporary use permits to Basecamp Hospitality, LLC and Wilson Investments, LLC for commercial activities on state trust lands. Teton County challenged these permits, arguing they should be subject to local land use regulations. The district court dismissed Teton County's challenge, stating the county lacked standing for judicial review. Subsequently, Teton County issued abatement notices to the permit holders, which led the Board to seek declaratory and injunctive relief, claiming sovereign immunity from local regulations.The Teton County Board of County Commissioners (Teton County) filed a petition for review, which was dismissed by the Ninth Judicial District Court. The Board then filed for declaratory judgment and injunctive relief in the First Judicial District, Laramie County, Wyoming. The district court issued a temporary restraining order and preliminary injunction against Teton County's enforcement actions. Citizens for Responsible Use of State Lands (CRUSL), formed by local property owners, sought to intervene, claiming their interests were directly impacted by the use of the state trust lands.The Wyoming Supreme Court reviewed the case. CRUSL argued it had a significant protectable interest due to the proximity of its members' properties to the state trust lands. However, the court found CRUSL's interests were contingent on the outcome of the sovereign immunity issue and thus not significant protectable interests. Additionally, the court held that Teton County adequately represented CRUSL's interests, as both sought to enforce local regulations on state trust lands. Consequently, the court affirmed the district court's denial of CRUSL's motion to intervene as a matter of right under Wyoming Rule of Civil Procedure 24(a)(2). View "Citizens for Responsible Use of State Lands v. State" on Justia Law

Husband and Wife married in 2012 and purchased a home in Cheyenne, Wyoming, in 2014. They shared the residence and paid the mortgage from a joint account. In 2021, they refinanced the home, and in December 2021, they separated. They discussed the division of their marital property without attorneys and obtained two appraisals for the home. Wife retained counsel to draft a stipulated divorce decree, which both parties signed. The decree awarded the home to Husband, with a provision that Wife would receive half the net proceeds if the home was sold or refinanced.The District Court of Laramie County granted the divorce and entered the Stipulated Decree in June 2022. Husband refinanced the home but did not pay Wife her share of the equity. Wife filed a motion for relief, claiming the decree entitled her to half the equity regardless of whether the home was sold or refinanced. The district court granted Wife relief under Rule 60, correcting the decree to reflect that any equity recognized through sale or refinance was to be equally divided.Husband appealed, and the Wyoming Supreme Court found the decree ambiguous and remanded the case for an evidentiary hearing. The district court held a hearing and found that both parties intended to split the equity in the home equally. The court awarded Wife half the equity, amounting to $106,323.40, and Husband appealed again.The Wyoming Supreme Court affirmed the district court's decision, finding that the clarification under Rule 60(a) was appropriate and did not modify the original judgment. The court also found that the district court's findings of fact and conclusions of law were sufficient and supported by the record. View "Van Vlack v. Van Vlack" on Justia Law

Charles Leonhardt, a pretrial detainee at the Big Horn County Jail, suffered from back pain and was eventually diagnosed with two lower back infections after being transported to a hospital. He sued Big Horn County Sheriff Ken Blackburn, Jail Captain Debbie Cook, unnamed detention officers, the Big Horn County Sheriff’s Office, and the Jail, alleging negligence and deliberate indifference under the Fourteenth Amendment.The District Court of Big Horn County granted summary judgment to the defendants on both claims. The court found that Sheriff Blackburn had fulfilled his duty to arrange for medical care by contracting with Midway Medical Clinic, which provided medical services to inmates. The court also determined that the actions of Sheriff Blackburn, Captain Cook, and the detention officers were reasonable and did not proximately cause Mr. Leonhardt’s injuries. Additionally, the court found no evidence of deliberate indifference to Mr. Leonhardt’s medical needs, as the defendants ensured he received timely medical care.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decision. The court held that there was no genuine dispute of material fact regarding the negligence claim, as the defendants acted reasonably and provided Mr. Leonhardt with access to medical care. The court also found no evidence that the defendants were aware of and disregarded an excessive risk to Mr. Leonhardt’s health, thus failing to meet the subjective component of a deliberate indifference claim. Consequently, the court affirmed the summary judgment in favor of the defendants on both the negligence and Fourteenth Amendment deliberate indifference claims. View "Leonhardt v. Big Horn County Sheriff's Office" on Justia Law

Joseph W. Russell entered a conditional guilty plea to possession of methamphetamine, reserving his right to appeal the constitutionality of a warrantless search conducted as he entered the Uinta County Courthouse. The search, performed by Deputy Dan Jensen, involved a magnetometer alerting to metal in Russell's waist area, leading to a pat-down and the discovery of a snus can containing methamphetamine. Russell was charged with felony possession of a controlled substance.The district court denied Russell's motion to suppress the evidence, finding the search reasonable under the Fourth Amendment. Russell entered a conditional guilty plea, allowing him to appeal the suppression order. He was sentenced to one to three years of imprisonment, suspended in favor of two years of supervised probation. Russell timely appealed the denial of his motion to suppress.The Wyoming Supreme Court reviewed the case, focusing on whether the search violated the Fourth Amendment. The court applied a three-part test to determine the reasonableness of the search: the nature and immediacy of the governmental concern, the efficacy of the search in addressing that concern, and the nature of the privacy interest upon which the search intrudes. The court found that courthouse security is a compelling governmental interest, the use of a magnetometer and follow-up searches are effective in addressing this concern, and the privacy interest in the snus can was minimal given the context of courthouse security.The court concluded that the search was reasonable and affirmed the district court's denial of Russell's motion to suppress. The holding emphasized that the search was justified under the special needs exception to the Fourth Amendment, balancing the government's interest in courthouse security against the minimal intrusion on Russell's privacy. View "Russell v. State" on Justia Law

Matthew Justin Olson was convicted by a jury of conspiracy to commit first-degree murder. Olson was incarcerated in the Platte County Detention Center on federal charges and had pending state charges for domestic violence against his ex-wife, SK, who was a key witness. Olson asked his cellmate, Danny Hendershott, to kill SK in exchange for a government stimulus check. Hendershott initially agreed but later reported the plot to law enforcement, leading to an undercover operation by the ATF. Olson was subsequently charged with conspiracy to commit first-degree murder.The District Court of Uinta County allowed the State to introduce evidence under Rule 404(b) of the Wyoming Rules of Evidence, indicating Olson had other serious charges pending. Olson objected, arguing this evidence was prejudicial. The court limited the State to stating Olson had four serious charges pending and SK was an important witness. Olson was found guilty and sentenced to life imprisonment. He appealed, claiming the district court erred in its pretrial ruling on the admissibility of the 404(b) evidence.The Supreme Court of Wyoming reviewed the case and found that the word "serious" was never actually introduced during the trial. The State's evidence was limited to stating Olson had pending charges without categorizing them as serious. The court held that Olson's substantial rights were not affected by the district court's pretrial ruling since the evidence presented at trial was in line with what Olson deemed appropriate. Consequently, any potential error in the pretrial ruling was deemed harmless. The Supreme Court of Wyoming affirmed Olson's conviction. View "Olson v. State" on Justia Law

Appellee filed a complaint against Appellant alleging breach of written agreements for the lease of oil storage tanks. During the bench trial, the district court amended the complaint to include an oral guarantee to pay for the leases, which Appellant was not allowed to rebut. The court found Appellant breached the oral guarantee and awarded damages to Appellee.The District Court of Campbell County initially found in favor of Appellee, determining that Appellant breached the oral guarantee and awarded $114,537.56 in damages. Appellant raised multiple issues on appeal, including the admission of evidence, the application of the statute of frauds, and the effect of a settlement with a co-defendant.The Supreme Court of Wyoming reviewed the case and found that the district court did not abuse its discretion in admitting various exhibits into evidence. The court also held that the statute of frauds defense was waived as it was not raised at trial. Additionally, the court found that the settlement with the co-defendant did not preclude Appellee from pursuing claims against Appellant.However, the Supreme Court of Wyoming determined that the district court abused its discretion by not allowing Appellant to testify regarding the oral guarantee. The court affirmed the district court's rulings on the other issues but reversed and remanded the case for the limited purpose of allowing Appellant to testify about the oral guarantee. The remand is specifically for reconsideration of the personal guarantee and to provide both parties an opportunity to introduce evidence on that issue. View "Sorum v. Sikorski" on Justia Law

Everett Bray was convicted of felony stalking his ex-wife, MS, in violation of Wyoming Statute § 6-2-506(b)(iv) and (e)(iv). After being released from prison for a prior domestic violence offense against MS, Bray went to MS’s residence in June 2022, despite being warned by the sheriff’s department not to trespass. He threatened MS and her mother, leading to his arrest and a no-contact order. In January 2023, Bray returned to MS’s property, violating the protection order, and attempted to take her dog, resulting in another arrest.The District Court of Converse County sentenced Bray to 42-84 months in prison after a jury found him guilty of felony stalking. Bray appealed, arguing that the State presented insufficient evidence to prove he had the specific intent to harass MS.The Wyoming Supreme Court reviewed the case, applying the standard that assumes the State’s evidence is true and gives the State the benefit of every favorable inference. The court found that Bray’s actions, including his threats and repeated visits to MS’s property despite warnings and a protection order, demonstrated a continuity of purpose and intent to harass. The court held that a rational jury could find Bray’s conduct showed specific intent to harass MS, affirming the conviction. View "Bray v. The State of Wyoming" on Justia Law

Joseph Lyle Fredrick was charged with multiple counts of possession of controlled substances and misdemeanor theft in June 2021. He pled guilty to felony possession of marijuana and misdemeanor possession of heroin, leading to the dismissal of other charges. The district court sentenced him to 117 days for the misdemeanor, with credit for time served, and three to five years for the felony, suspended for three years of supervised probation. His probation was transferred to Oregon.In September 2023, the State filed a petition to revoke Fredrick’s probation, alleging he absconded and had no contact with his probation officer after July 2023. He was arrested in Oregon in November 2023, transported to Wyoming in December, and remained in custody. The district court held an initial appearance on December 19 and set an adjudication hearing for December 27. The State moved to allow the probation officer to testify by video, which the court granted. The hearing was continued to January 5, 2024, due to discovery issues and the probation officer’s failure to appear.At the January 5 hearing, the probation officer testified by video, and Fredrick moved to dismiss the revocation petition due to discovery violations. The court denied the motion but continued the hearing to January 19 to resolve the discovery dispute. On January 19, the court denied Fredrick’s motion to dismiss, found certain documents privileged, and concluded there was good cause for the continuances. The court revoked Fredrick’s probation and reinstated his three- to five-year sentence, with credit for time served.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court held that the district court did not abuse its discretion in extending the revocation hearing beyond the 15-day limit, allowing the probation officer to testify by video, and determining that certain probation records were privileged. The court also found that the discovery dispute did not warrant dismissal of the petition. View "Fredrick v. The State of Wyoming" on Justia Law