Justia Wyoming Supreme Court Opinion Summaries
Hammell v. The State of Wyoming
Clint Wayne Hammell pled guilty to felony possession of methamphetamine in May 2023 and was sentenced to four to five years of imprisonment, suspended in favor of three years of supervised probation. His probation was revoked twice in November 2023 and February 2024, with his sentence resuspended each time. After the second revocation, he was ordered to apply for and complete an adult community corrections (ACC) program, which he did at the Casper Re-Entry Center (CRC).In April 2024, the State petitioned to revoke Hammell's probation again, alleging he failed to report to a scheduled appointment with his probation agent on March 26, 2024, and did not return to the CRC, leading to his classification as an escapee. At the evidentiary hearing, his probation agent testified about his absence and subsequent arrest on March 28. The CRC case manager supervisor and a Casper Police Department officer also testified about his failure to report and his arrest.The district court found that Hammell violated his probation conditions and that his violations were willful, noting his failure to use his phone to arrange transportation back to the CRC. Consequently, the court revoked his probation and imposed the underlying sentence of four to five years with credit for time served. Hammell appealed the decision.The Supreme Court of Wyoming reviewed the case, focusing on whether the district court abused its discretion in finding Hammell's violations willful. The court upheld the district court's decision, stating that the evidence supported the finding of willfulness, as Hammell did not make efforts to contact his probation agent or return to the CRC. The court affirmed the revocation of Hammell's probation. View "Hammell v. The State of Wyoming" on Justia Law
Posted in:
Criminal Law
Aune v. State
Carolyn Aune was convicted of first-degree murder following the death of PW, a two-year-old child, due to child abuse. On March 27, 2021, PW was brought to the emergency room by her father, Moshe Williams, unresponsive and with multiple injuries, including bruises, fractures, and a transected small intestine. Despite being life-flighted to Children’s Hospital in Denver, PW succumbed to her injuries on April 4, 2021. The autopsy revealed that PW died from blunt force trauma to the abdomen, leading to sepsis and organ failure.The District Court of Park County charged both Williams and Aune with aggravated child abuse, later amended to first-degree murder after PW’s death. Aune’s trial was severed from Williams’s. During the trial, Aune testified that she witnessed Williams inflict the fatal injury on PW but did not seek medical help, believing PW was fine. The State argued that Aune either intentionally or recklessly caused PW’s injuries by failing to get prompt medical attention, which led to PW’s death.The Wyoming Supreme Court reviewed the case, focusing on whether the State presented sufficient evidence to support Aune’s conviction for felony child abuse as a requisite offense for first-degree murder and whether the prosecutor committed misconduct by misstating the law. The court found that the State provided sufficient evidence showing Aune recklessly inflicted physical injury on PW by failing to seek medical care, which led to PW’s death. The court also determined that the prosecutor did not misstate the law, as the statutes in question encompass injuries inflicted through acts of omission.The Wyoming Supreme Court affirmed Aune’s conviction, holding that the evidence supported the jury’s finding that Aune’s failure to seek medical care for PW constituted reckless infliction of physical injury, leading to PW’s death and justifying the first-degree murder conviction. View "Aune v. State" on Justia Law
Posted in:
Criminal Law
Hogan & Associates Builders, LLC v. Eiden Construction, LLC
Eiden Construction, LLC (Eiden) entered into a subcontract with Hogan & Associates Builders, LLC (Hogan) for earthwork and utilities on a school construction project. Hogan sued Eiden and its bonding company, AMCO Insurance Company (AMCO), for breach of contract, claiming Eiden failed to complete its work, including draining sewage lagoons and constructing a fire pond. Eiden counterclaimed for unpaid work, arguing it was not responsible for draining the lagoons and that Hogan did not comply with the subcontract’s notice and opportunity to cure provisions. AMCO argued it was not liable under the performance bond because Eiden did not breach the subcontract and Hogan did not provide proper notice.The District Court of Uinta County found for Hogan on the claim regarding the sewage lagoons but not on other claims, ruling AMCO was not liable under the bond due to lack of notice. Eiden and Hogan both appealed. Eiden argued the court erred in finding it responsible for draining the lagoons and in awarding Hogan damages billed to an associated company. Hogan contended the court erred in not awarding damages for other work and in its calculation of prejudgment interest.The Wyoming Supreme Court affirmed the lower court’s decision. It held Eiden breached the subcontract by not draining the lagoons and that Hogan was entitled to recover costs for supplementing Eiden’s work. The court found Eiden’s late completion of the septic system justified Hogan’s directive to expedite lagoon drainage. It also ruled Hogan properly paid the supplemental contractors, despite invoices being sent to an associated company. The court rejected Hogan’s claims for additional damages, concluding Eiden complied with the notice to cure provisions for the fire pond and other work. The court also upheld the lower court’s calculation of prejudgment interest, applying the offset before calculating interest. View "Hogan & Associates Builders, LLC v. Eiden Construction, LLC" on Justia Law
Hayes v. State
Vincent Hayes was convicted of second-degree murder for shooting and killing his father, William Johnson, during an argument at their home in Casper, Wyoming. Hayes claimed he acted in self-defense, believing his father was about to shoot him. After the shooting, Hayes attempted to clean up the scene, hid the weapon, and initially fabricated a story about an intruder. He later admitted to the police that he made up the story because he thought no one would believe his self-defense claim.The District Court of Natrona County instructed the jury that it could infer malice from Hayes' use of a deadly weapon, despite his self-defense claim. Hayes did not object to this instruction at trial. The jury found Hayes guilty of second-degree murder, and he was sentenced to 50 to 75 years in prison.The Wyoming Supreme Court reviewed the case, focusing on whether the district court committed plain error by instructing the jury that it could infer malice from the use of a deadly weapon. The court held that the instruction was proper and did not violate any clear and unequivocal rule of law. The instruction was consistent with Wyoming precedent, which allows for permissive inference instructions if they are not mandatory and the state still bears the burden of proving each element of the crime beyond a reasonable doubt. The court found that the connection between the use of a deadly weapon and the inference of malice was justified by the facts of the case. Consequently, the Wyoming Supreme Court affirmed Hayes' conviction. View "Hayes v. State" on Justia Law
Posted in:
Criminal Law
Boot Ranch, LLC v. Wagonhound Land & Livestock Co., LLC
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
Posted in:
Real Estate & Property Law
Aisenbrey v. State
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
Citizens for Responsible Use of State Lands v. State
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
Van Vlack v. Van Vlack
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
Posted in:
Civil Procedure, Family Law
Leonhardt v. Big Horn County Sheriff’s Office
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
Russell v. State
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
Posted in:
Constitutional Law, Criminal Law