Justia Wyoming Supreme Court Opinion Summaries

Police investigating a sexual assault executed a search warrant at a mobile home occupied by three individuals, including the appellant. During the search of one resident’s bedroom, officers found a glass pipe believed to contain methamphetamine residue. The appellant and his mother, who also lived in the home, denied the presence of drugs when questioned. Based on the discovery, law enforcement obtained a second warrant to search the entire residence for controlled substances. This second search led to the discovery of methamphetamine and drug paraphernalia in a bench located in the appellant’s bedroom, resulting in his arrest and charge for felony possession.The District Court of Campbell County presided over the criminal case. The appellant filed a motion to suppress the evidence, arguing that the officer’s affidavit for the second search warrant omitted material facts, such as the pipe being found in a locked bedroom accessible only to one resident, and that these omissions undermined probable cause. After a hearing, the district court denied the motion, finding that the omitted facts would not have defeated probable cause, as the resident in whose room the pipe was found could access the entirety of the home, including the appellant’s bedroom. The appellant then entered a conditional guilty plea, reserving the right to appeal the suppression ruling.Reviewing the appeal, the Supreme Court of Wyoming affirmed the district court’s decision. It held that even if the omitted facts had been included in the affidavit, probable cause existed to search the entire mobile home because the resident implicated by the initial pipe discovery had access throughout the home. The Court concluded that the district court did not err in denying the motion to suppress, and the conviction was affirmed. View "Urrutia v. State" on Justia Law

The case concerns a defendant who was charged with felony interference with a peace officer and, after pleading guilty, was placed on supervised probation with a suspended prison sentence. Over the next few years, the defendant’s probation was twice revoked and reinstated, with the court imposing varying conditions in response to admitted violations, including substance use and other misconduct. After the defendant was given additional chances, including substance abuse treatment and a split sentence, the State eventually filed a third petition to revoke probation, alleging further violations such as drug use, failure to attend probation meetings, and inadequate progress in treatment.Following the third petition, the District Court of Goshen County held an adjudicatory hearing to determine whether the defendant violated probation terms. Both parties presented evidence and argument on the alleged violations. After the hearing, the district court found that the violations were proven by a preponderance of the evidence and that the defendant’s actions were willful. The court then immediately revoked probation and imposed the previously suspended prison sentence, without conducting a separate dispositional phase or allowing the defendant to present mitigation.The Supreme Court of Wyoming reviewed the case under the plain error standard because the defendant did not object during the proceedings. The court held that, although Wyoming law does not require separate hearings for adjudication and disposition in probation revocation matters, both phases must be conducted with appropriate opportunity for mitigation and consideration of willfulness. The district court erred by failing to conduct the dispositional phase, denying the defendant procedural rights and undermining the fairness of the proceedings. The Supreme Court reversed the district court’s order and remanded for a proper disposition hearing in accordance with Wyoming law. View "Velasquez v. The State of Wyoming" on Justia Law

In 1979, the appellant and his brother took a truck in Laramie, Wyoming, and drove it to Casper. The appellant pled guilty to felony Unauthorized Use of Automobile. The district court sentenced him, suspended the sentence, and placed him on probation. It further ordered that upon successful completion of one year of probation, he could withdraw his guilty plea and have the matter dismissed. After completing probation, the appellant was discharged, his guilty plea was withdrawn, and the case was dismissed. Despite this, the Wyoming Division of Criminal Investigation maintained records incorrectly indicating he was a convicted felon.In 2025, the appellant petitioned the District Court of Albany County to expunge his records under Wyo. Stat. Ann. § 7-13-1502, which provides for expungement of felony convictions. The State did not oppose the petition. The district court denied the request, reasoning that the appellant’s case was resolved through a deferred prosecution process—specifically, the withdrawal of the guilty plea and dismissal after probation—under statutes governing deferred dispositions. It concluded that, as there was no felony conviction, there was no conviction to expunge. The appellant’s motion to reconsider was also denied, and he appealed.The Supreme Court of Wyoming reviewed the case and applied a de novo standard to statutory interpretation. It held that Wyo. Stat. Ann. § 7-13-1502 unambiguously limits expungement eligibility to persons convicted of felonies. The court determined that a deferred prosecution resulting in annulment or withdrawal of a guilty plea and dismissal does not constitute a conviction. Therefore, the appellant is not eligible for expungement under this statute. The Supreme Court of Wyoming affirmed the district court’s denial of the expungement petition. View "Lynch v. The State of Wyoming" on Justia Law

The defendant was charged with two counts of witness intimidation under Wyoming law, based on statements made during a supervised visit with his two daughters and a subsequent Facebook post. The daughters, aged 14 and 11, were residing at a youth home and scheduled to testify at an upcoming Child in Need of Supervision (CHINS) hearing. During the visit, the defendant made comments such as threatening to take away a tablet if one daughter refused to visit, and asked how the girls would feel if he took their kids away. He also referenced his right to bear arms and posted a Facebook rant containing generically threatening statements. Witnesses at the youth home perceived some of the remarks as threatening, but the daughters themselves did not clearly connect the comments to their upcoming court appearance.The District Court of Uinta County presided over the criminal trial. The jury convicted the defendant on both counts of witness intimidation under Wyo. Stat. Ann. § 6-5-305(a), and the judge sentenced him to concurrent prison terms of four to eight years. The defendant appealed, arguing that there was insufficient evidence to support the convictions and that his statements did not constitute actionable threats intended to influence or intimidate the witnesses in relation to their duty to testify.The Supreme Court of Wyoming reviewed the case. Applying the standard that witness intimidation under the statute is a specific intent crime, the court determined that the evidence did not establish that the defendant’s statements were intended to influence, intimidate, or impede his daughters in their roles as witnesses. The court found no nexus between the alleged threats and the daughters’ participation in the CHINS hearing. Accordingly, the Supreme Court of Wyoming held that the evidence was insufficient to sustain the convictions and reversed both counts. View "Brown v. State" on Justia Law

The case concerns a child, DC, who was removed from his parents’ care shortly after birth due to substantiated concerns about neglect, failure to thrive, domestic violence, mental health issues, substance abuse, and instability within the family. The child was placed with maternal grandparents, and a permanency plan for family reunification was established. The father, AC, was given a case plan with specific requirements addressing sobriety, mental health, parenting skills, stable housing, and employment. Over the next eighteen months, the father was incarcerated for nearly a year of that period, including a new sentence of five to seven years for felony offenses. He failed to make consistent progress on his case plan goals, particularly concerning mental health and substance abuse treatment, employment, and securing stable housing.The District Court of Platte County—sitting as a juvenile court—initially ordered reunification, then shifted to a concurrent goal of reunification and adoption as the father’s progress stalled and his incarceration continued. The Department of Family Services documented extensive, tailored efforts to facilitate reunification, including arranging for services while the father was both in and out of custody. Despite these efforts, the father did not meaningfully participate in or complete the required treatment, counseling, or parenting programs. At an evidentiary review hearing, the court found the Department’s efforts reasonable and accessible, and that it was in the child’s best interests to change the permanency plan to adoption. The father appealed the change, arguing insufficient efforts were made to accommodate his incarceration.The Supreme Court of Wyoming reviewed the juvenile court’s decision for abuse of discretion. It held that the Department made reasonable efforts to reunify father and child, even considering the constraints of incarceration, and that the child’s need for stability outweighed the father’s incomplete progress. The court affirmed the juvenile court’s order changing the permanency plan to adoption. View "In the Interest Of: DC" on Justia Law

In 2023, Wyoming enacted two laws restricting abortion: the Life is a Human Right Act, which broadly banned abortion procedures with limited exceptions, and a separate statute prohibiting the prescription or use of drugs to induce abortions, also with exceptions. These laws imposed criminal and civil penalties on violators, excluding the pregnant person. After the laws took effect, several plaintiffs—including medical professionals, non-profit organizations, and an individual woman—challenged the statutes in District Court of Teton County, arguing they violated Article 1, Section 38 of the Wyoming Constitution, which guarantees each competent adult the right to make their own health care decisions.The district court granted summary judgment in favor of the plaintiffs, finding that the challenged laws unreasonably and unnecessarily infringed on the constitutional right to make health care decisions, and issued a permanent injunction preventing enforcement of the abortion restrictions. The State of Wyoming appealed directly to the Wyoming Supreme Court.The Wyoming Supreme Court, exercising de novo review, held that the decision to terminate or continue a pregnancy is a health care decision protected by Article 1, Section 38. The Court determined that this provision confers a fundamental right, and that statutes restricting it must satisfy strict scrutiny: the State must show such laws are narrowly tailored to achieve a compelling governmental interest and use the least restrictive means. The majority found that the State failed to present sufficient evidence that the abortion restrictions and their exceptions were the least restrictive means of protecting prenatal life. Accordingly, the Wyoming Supreme Court affirmed the district court’s ruling, holding the 2023 abortion laws unconstitutional under the Wyoming Constitution. View "State of Wyoming v. Johnson" on Justia Law

The case concerns a property owner who challenged the assessed valuation of his residential property by the county assessor. After receiving a tax assessment notice valuing his home at $732,661, the property owner met with the assessor to contest the figure, citing his home’s 2013 purchase price as more accurate. The assessor, after review, reduced the assessment twice—first lowering the quality rating of the home and then making a minor adjustment for siding type—ultimately setting the value at $674,465. The property owner appealed the assessment, objecting to the timing of evidence disclosure by the assessor and arguing that the assessed value should reflect actual sales in the neighborhood or a realtor’s market evaluation instead of the mass appraisal system used.The Laramie County Board of Equalization held a hearing on the appeal, admitting both parties’ evidence, including the assessor’s exhibits, which were received by the property owner three days later than the statutory deadline but still twenty-seven days before the hearing. The Board found the assessor’s methods and use of the state-mandated Computer Assisted Mass Appraisal (CAMA) system proper, and concluded that the property owner failed to provide credible evidence that the valuation was incorrect or unlawful. The Board affirmed the assessment. The property owner appealed to the State Board of Equalization, which remanded briefly for procedural reasons, after which the Board reaffirmed its decision. The State Board and then the District Court of Laramie County both affirmed.The Supreme Court of Wyoming reviewed the case and held that the County Board did not abuse its discretion in admitting the assessor’s evidence, given the minimal delay and lack of prejudice. It also held that the property owner did not meet his burden to rebut the presumption of correctness in the assessor’s valuation, which was supported by substantial evidence and in accordance with law. The Supreme Court affirmed the lower courts’ decisions. View "Johnston v. Ernst" on Justia Law

Timothy Hale and Sonja Ringen constructed a storage building on their commercially zoned property in Laramie without first obtaining a building permit. When the City of Laramie discovered the construction, it issued a stop work order and a cease-and-desist letter. Despite these notices, Hale and Ringen continued building and subsequently applied for a permit, which the City denied due to deficiencies in the application. After further unsuccessful permit attempts and ongoing disputes over the City’s requirements—including requests for disassembly of the structure—the City sought and obtained a permanent injunction from the District Court of Albany County, restricting use of the building until permitting was complete and compliance was achieved.The District Court of Albany County conducted a bench trial in May 2022 and granted the City’s request for a permanent injunction. The court outlined a process for inspections, identification of code violations, and corrective actions, but continued conflict between the parties hindered progress. Multiple rounds of correspondence, inspections, and motions ensued, with the City insisting on structural disassembly and Hale/Ringen providing documentation to support their position. Hale and Ringen eventually moved to vacate the injunction, arguing it was no longer equitable given their efforts and the City’s refusal to issue a permit. The district court denied their motion, citing only the parties’ lack of agreement, and provided no substantive analysis of the evidence.On appeal, the Supreme Court of Wyoming determined that the district court abused its discretion by failing to consider the evidence and arguments presented before denying the motion to vacate or modify the injunction. The Supreme Court held that a court must exercise discretion and decide motions on their merits, rather than requiring agreement between adversarial parties. Consequently, the Supreme Court reversed the district court’s order and remanded the case for full consideration of Hale/Ringen’s motion in light of all relevant facts and equities. View "Hale v. City of Laramie" on Justia Law

Russ and Debi Ropken hired a construction company to build a custom home based on an oral agreement. The contractor began work and sent invoices for services and materials, which the Ropkens paid until May 2022, after which they stopped making payments. In July 2022, the Ropkens removed the contractor from the site. The contractor then sent a demand letter for three unpaid invoices totaling $276,169, but the Ropkens refused to pay. The contractor sued to recover the unpaid amount.In the District Court of Park County, the Ropkens admitted owing at least $176,870.21. At the conclusion of a jury trial, the jury found there was a valid contract, the Ropkens had breached it, and awarded the contractor $258,587.70 in damages. The district court entered judgment for that amount and permitted the contractor to request prejudgment interest. The contractor timely filed for prejudgment interest, and the Ropkens objected. The district court found for the contractor, awarding $33,473.25 in prejudgment interest at a statutory rate, and calculated interest from the date of the demand letter. The Ropkens paid the judgment but appealed the prejudgment interest award.The Supreme Court of Wyoming reviewed whether the district court erred in awarding prejudgment interest and whether due process was violated by granting interest without an evidentiary hearing. The court held that a district court may award prejudgment interest even when it is not the trier of fact, as prejudgment interest is a matter of law and not fact. The court found the claim was liquidated and the Ropkens had notice. The court also held that the Ropkens received adequate notice and opportunity to be heard, satisfying due process. The Supreme Court of Wyoming affirmed the award of prejudgment interest. View "Ropken v. Yj Construction, Inc." on Justia Law

After marrying in July 2014, a husband and wife executed a postnuptial agreement two days after their wedding, intending to keep their respective properties separate during the marriage. Prior to marriage, they jointly purchased land, with the wife contributing a down payment and the remainder financed by a mortgage. After marriage, they constructed a home and acquired several vehicles, with the husband contributing substantially more toward improvements and purchases. The couple separated in late 2020, and the husband filed for divorce in early 2021. Disputes arose concerning the enforceability and interpretation of the postnuptial agreement, as well as the division and valuation of marital assets, especially the marital residence.The District Court of Albany County first granted summary judgment, finding the postnuptial agreement enforceable, rejecting the wife’s arguments of unconscionability and unilateral mistake due to lack of sufficient evidence. However, the court denied the husband’s subsequent request for summary judgment on the property distribution, interpreting the agreement to allow equitable division of assets acquired during the marriage. After a bench trial, the court divided the vehicles and the marital residence between the parties, awarded credits for their respective contributions, and ordered a current appraisal to determine the property’s value for final division. The court ultimately set the marital residence’s value at $925,000 and split the remaining equity equally after accounting for the parties’ contributions.On appeal, the Supreme Court of Wyoming affirmed the district court’s rulings. It held that the postnuptial agreement was enforceable, that its terms required the court to exercise discretion in distributing property acquired during the marriage, and that there was no abuse of discretion in the court’s valuation and division of the marital residence. The Supreme Court found the lower court’s findings and application of the law to be proper and supported by the record. View "Young v. Jones" on Justia Law