Justia Wyoming Supreme Court Opinion Summaries

Samuel Nania was convicted by a jury of third-degree sexual assault. He appealed, arguing that the district court erred by excluding evidence of his polygraph examination during the trial. Nania contended that the district court should have analyzed the reliability of the polygraph examination before excluding it.The district court of Natrona County held a hearing on the State's motion in limine to exclude the polygraph evidence. The court granted the State's motion, ruling that polygraph testimony is inadmissible in Wyoming without a stipulation by the parties. Nania did not make a formal offer of proof regarding the polygraph results or the qualifications of the examiner, nor did he request a Daubert hearing to establish the reliability of the polygraph evidence.The Wyoming Supreme Court reviewed the case and upheld the district court's decision. The court noted that Nania failed to provide a sufficient record to review the polygraph results or the qualifications of the examiner. The court also emphasized that Wyoming precedent requires a stipulation for the admissibility of polygraph evidence and that Nania did not meet this requirement. Additionally, the court found that even if the district court had erred, Nania did not demonstrate that the exclusion of the polygraph evidence prejudiced the outcome of the trial. The court concluded that there was no reasonable probability that the verdict would have been more favorable to Nania had the polygraph evidence been admitted, given the substantial evidence against him, including his own admissions and witness testimonies.The Wyoming Supreme Court affirmed the district court's decision, holding that the exclusion of the polygraph evidence was not an abuse of discretion and did not result in prejudicial error. View "Nania v. The State of Wyoming" on Justia Law

Chesapeake Exploration, LLC (Chesapeake) and Morton Production Company, LLC (Morton) entered into a joint operating agreement for oil and gas development in Converse County, Wyoming. Morton sued Chesapeake for breach of contract, violation of the Wyoming Royalty Payment Act (WRPA), and conversion after Chesapeake adjusted Morton’s ownership interest and withheld production proceeds. Chesapeake counterclaimed for breach of contract, unjust enrichment, and breach of the implied covenant of good faith and fair dealing. The district court granted summary judgment in favor of Morton.Chesapeake appealed, challenging the district court’s summary judgment on Morton’s breach of contract claim, the supplemental decision on Chesapeake’s counterclaims and affirmative defenses, and the determination that Chesapeake violated the WRPA. The Wyoming Supreme Court reviewed the case.The Wyoming Supreme Court affirmed the district court’s decision. It held that Chesapeake breached the contract by adjusting Morton’s ownership interest and billing for costs beyond the twenty-four-month limitation period specified in the 1985 COPAS Form, which was incorporated into the joint operating agreement. The court found the language in the COPAS Form unambiguous and declined to consider extrinsic evidence. The court also upheld the district court’s use of Rule 60(a) to correct a clerical error in its original order and found that Chesapeake’s counterclaims were properly dismissed as they were rendered moot by the summary judgment on Morton’s claims. Additionally, the court ruled that Chesapeake violated the WRPA by withholding production proceeds without placing the disputed funds in escrow, as required by the statute. View "Chesapeake Exploration, LLC, v. Morton Production Company, LLC" on Justia Law

The State of Wyoming filed a petition against MF (Mother) and JF (Father) on June 22, 2020, alleging neglect of their minor children, JF and TF. Following a shelter care hearing, the juvenile court removed the children from the home and placed them in foster care. After a disposition hearing, the children remained in the custody of the Department of Family Services (the Department), with a permanency plan of family reunification. On January 19, 2024, after an evidentiary permanency hearing, the juvenile court changed the permanency plan to adoption.The juvenile court found that the Department had made reasonable efforts to reunify the family, but these efforts were unsuccessful. The court noted that Mother had made some progress but ultimately failed to consistently address the children's needs and safety concerns. The court also found that the children's best interests were served by changing the permanency plan to adoption, given their progress in foster care and the lack of stability and safety in Mother's care.The Wyoming Supreme Court reviewed the case and affirmed the juvenile court's decision. The court held that the juvenile court did not abuse its discretion in changing the permanency plan to adoption, as the Department had made reasonable efforts at reunification, which were unsuccessful. The court also found that the juvenile court's decision to cease reunification efforts with Mother was supported by Wyoming law, which allows for discontinuation of such efforts when they are inconsistent with the permanency plan.Additionally, the Wyoming Supreme Court held that Mother's due process rights were not violated by the denial of a continuance of the permanency hearing or by the juvenile court's evidentiary rulings. The court found that Mother had adequate notice and opportunity to be heard, and the juvenile court's decisions were within the bounds of reason. The court also declined to adopt Mother's request for a change in procedures to require compliance with the Wyoming Rules of Evidence in evidentiary permanency hearings. View "In the Interest of: JF v. The State of Wyoming" on Justia Law

Anthony Torres was convicted by a jury of twelve counts of sexual abuse of a minor. He appealed, arguing that the district court abused its discretion by allowing the State to amend its Information to add three additional charges of sexual abuse ten days before trial and by admitting three excerpts of a videotaped forensic interview of one of the minors into evidence.The District Court of Sweetwater County initially charged Torres with ten counts of sexual abuse involving his stepson, GT. Later, the State added a charge involving another minor, LT. Shortly before trial, the State moved to amend the Information to include three more charges based on new disclosures by LT. The district court granted the motion and continued the trial to a later date, which Torres' counsel agreed to. Torres was ultimately tried on fourteen counts and convicted on twelve.The Wyoming Supreme Court reviewed the case. It held that the district court did not abuse its discretion in allowing the State to amend the Information. The court noted that the trial was continued to a date agreed upon by Torres' counsel, providing sufficient time to prepare a defense. The court also found that the amendments did not change Torres' defense strategy, which was to argue that the minors were influenced to fabricate their stories.Regarding the admission of the videotaped forensic interview excerpts, the court held that the district court did not abuse its discretion. The excerpts were admitted as prior consistent statements under Wyoming Rule of Evidence 801(d)(1)(B) to rebut charges of recent fabrication or improper influence. The court found that the statements were sufficiently consistent with the minors' trial testimony and that their admission was not unduly prejudicial.The Wyoming Supreme Court affirmed the district court's decisions, upholding Torres' convictions. View "Torres v. The State of Wyoming" on Justia Law

Wesley Brinda (Father) petitioned for a custody modification to change the current arrangement from primary residential custody with Stacey Walker (Mother) to shared residential custody. Mother counterpetitioned to modify child support. After a two-day bench trial, the district court found no material change in circumstances to justify reopening the current custodial order but modified the child support order. Father appealed the district court’s custody decision.The District Court of Campbell County initially awarded joint legal custody with Mother having primary residential custody of the children, AB and KB, based on Father’s rotating work schedule at a coal mine. After being laid off in 2016, Father became self-employed, allowing him more flexibility. In 2017, Father successfully petitioned to modify child support but did not request a custody modification. In 2021, Father filed a petition to modify custody, citing his flexible work schedule and the children’s desire to spend more time with him. Mother denied sufficient grounds for modifying custody but sought a review of child support.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decision. The court held that the district court did not abuse its discretion in determining no material change in circumstances had occurred. The court found that while the children expressed a desire to spend more time with Father, the district court reasonably concluded that these preferences, along with Father’s career change, did not justify reopening the custody order. The court also found that the parties generally co-parented well and that the district court properly considered all evidence presented. The Wyoming Supreme Court affirmed the district court’s decision, finding it reasonable and supported by the evidence. View "Brinda v. Walker" on Justia Law

Kenneth Charles Hoffman was convicted by a jury of five counts of sexual abuse of his minor stepdaughter, SD. The incident occurred on March 10, 2023, when SD, after consuming alcohol and marijuana provided by Hoffman, was sexually assaulted by him. The next morning, SD reported the incident, and a sexual assault examination revealed seminal fluid on a tampon she had used, though the DNA was insufficient to identify its source. SD had disclosed to law enforcement that she had been sexually active with someone else about a week and a half before the incident.The District Court of Weston County reviewed the case and denied Hoffman's motion to introduce evidence of SD’s prior sexual activity, which he argued would explain the presence of the seminal fluid. The court ruled that the probative value of this evidence did not outweigh its prejudicial effect, as required by Wyoming’s rape shield statute. Consequently, Hoffman was found guilty on all charges and sentenced to 40 to 50 years in prison.The Supreme Court of Wyoming reviewed the case and upheld the lower court's decision. The court held that the district court did not abuse its discretion in excluding the evidence of SD’s prior sexual activity. The Supreme Court noted that Hoffman failed to establish a material connection between the prior sexual activity and the seminal fluid found, as the DNA evidence neither included nor excluded him. The court affirmed that the probative value of the evidence did not substantially outweigh its prejudicial effect, thus affirming Hoffman's conviction and sentence. View "Hoffman v. The State of Wyoming" on Justia Law

Danny Jarvis pled guilty to burglary in violation of Wyoming law. Before sentencing, he filed a motion to withdraw his guilty plea, which the district court denied. He was subsequently sentenced to seven to ten years in prison. Jarvis appealed, claiming the district court abused its discretion by denying his motion to withdraw his guilty plea.The district court of Weston County initially set Jarvis' bond at $10,000 cash, which was later reduced to a $10,000 personal surety bond to allow him to seek employment and attend drug treatment. Jarvis entered residential drug treatment but left to obtain medical care. At the change of plea hearing, Jarvis agreed to plead guilty to burglary in exchange for the dismissal of a felony property destruction charge. He confirmed there was no plea agreement regarding his sentence other than owing restitution. The court accepted his guilty plea after ensuring it was made knowingly and voluntarily.Jarvis later filed a pro se motion to withdraw his guilty plea, claiming he was promised a "global deal" that included the dismissal of a DUI charge in a separate case. He argued this promise was not fulfilled, rendering his plea involuntary. The district court held a hearing, allowed Jarvis to proceed pro se, and took the motion under advisement. The court ultimately denied the motion, finding Jarvis failed to show a fair and just reason for withdrawal under Wyoming Rule of Criminal Procedure 32(d).The Wyoming Supreme Court reviewed the case and affirmed the district court's decision. The court found that Jarvis did not assert his innocence, the State would not be prejudiced by withdrawal, and the delay in filing the motion was not substantial. However, the court determined Jarvis received close assistance of counsel, his plea was knowing and voluntary, and allowing withdrawal would waste judicial resources. The court concluded that the district court did not abuse its discretion in denying Jarvis' motion to withdraw his guilty plea. View "Jarvis v. The State of Wyoming" on Justia Law

In August 2021, Sean Halling applied for a variance from the Town of Afton to build an accessory building larger than the 900 square feet allowed by the local development code. The variance was approved by the Town Council in September 2021. In February 2022, the Zoning Administrator approved a modification to increase the building's size without public notice. The appellants, neighbors of Mr. Halling, observed the construction and became concerned about the building's size and potential use. They sent a letter to the Town in October 2022 and filed a declaratory judgment action in December 2022.The District Court of Lincoln County dismissed the appellants' action, concluding they failed to exhaust administrative remedies and that the matter was moot due to changes in the local development code allowing buildings of the size in question without a variance. The appellants appealed the decision.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision. The court held that the appellants were required to exhaust administrative remedies specified in the Afton Land Development Code before seeking judicial intervention. The court found that the appellants did not appeal the Zoning Administrator's decision to the Town Council acting as the Board of Adjustment within the required timeframe. The court also concluded that the Town Council was acting in its capacity as the Board of Adjustment when it approved the initial variance, and the appellants failed to appeal that decision within a reasonable time. The court emphasized the importance of following prescribed administrative processes for resolving zoning disputes. View "Sorensen v. Halling" on Justia Law

Nicholas Hull sued North Lincoln Hospital District and several medical professionals for negligence in the death of his newborn son, Eli Hull. Canessa Hull, Nicholas's wife, went into labor on August 9, 2021, and was admitted to Star Valley Health. Due to complications during labor, Eli was born with a double-knotted nuchal cord and did not survive. The Hulls were initially informed by the attending doctors that the nuchal cord was the sole cause of Eli's death. However, in April 2023, Dr. Burk, an anesthesiologist, revealed that Eli's death was preventable and due to the failure to follow safety protocols during labor.The District Court of Lincoln County dismissed Mr. Hull’s complaint, ruling that his notice of governmental claim was untimely. The court found that the two-year period for filing the notice expired in September 2023, and Mr. Hull’s notice, submitted in July 2023, was defective. Mr. Hull argued that the period should be equitably extended due to the defendants' fraudulent concealment of the true cause of Eli’s death.The Supreme Court of Wyoming reviewed the case and affirmed the lower court's decision. The court held that Mr. Hull’s complaint did not adequately allege the elements required for equitable estoppel or equitable tolling. Specifically, the complaint failed to show that the delay in filing the notice was induced by the defendants' misinformation and that Mr. Hull acted on this misinformation in good faith, resulting in his failure to file a timely notice. Additionally, the complaint did not establish that the fraudulent concealment prevented Mr. Hull from complying with the statutory deadline, as he had over four months remaining to file a proper notice after discovering the concealment. Therefore, the court concluded that neither equitable estoppel nor equitable tolling applied, and the dismissal of the complaint was affirmed. View "Hull v. North Lincoln Hospital District" on Justia Law

Monique Huia Sullivan was convicted of voluntary manslaughter for the stabbing death of her fiancé, Andrew Moore. The couple, both sheep shearers from Australia and New Zealand, respectively, were part of a shearing crew working in Wyoming. On February 20, 2023, after a series of arguments and a difficult couple of days, Sullivan stabbed Moore once in the left side with a large kitchen knife. Sullivan was charged with second-degree murder, but the trial focused on whether she acted maliciously or in self-defense.The District Court of Lincoln County allowed John Moore, the victim's father, to testify and admitted a photograph of Moore while he was alive. Sullivan objected to both, arguing they were irrelevant and prejudicial. The court overruled her objections, and the jury found her guilty of voluntary manslaughter. She was sentenced to 12 to 17 years in prison.The Supreme Court of Wyoming reviewed the case and addressed two main issues: whether the district court abused its discretion in admitting the father's testimony and the photograph, and whether the prosecutor committed misconduct by advocating for their admission. The court found that the father's testimony about Moore's demeanor, favorite vacation spots, and the family dog was irrelevant and should not have been admitted. Similarly, the photograph was deemed irrelevant and should not have been admitted in the State's case-in-chief.However, the court concluded that the admission of this evidence was harmless error and did not materially prejudice Sullivan. The State's case was strong, with multiple witnesses and Sullivan's own admissions undermining her self-defense claim. The court also found no prosecutorial misconduct, as Sullivan failed to establish material prejudice from the prosecutor's actions. The Supreme Court of Wyoming affirmed the lower court's decision. View "Sullivan v. The State of Wyoming" on Justia Law