Justia Wyoming Supreme Court Opinion Summaries

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The Supreme Court reversed the order of the district court granting Tanya Knell's application for issuance of a writ of continuing garnishment of Bruce Knell's wages and enforcing the writ, holding that the garnishment exceeded the limits on creditor garnishments. Tanya applied for a writ of garnishment against Bruce's earnings for amounts owing under a property division ordered by the district court. The district court ruled that the garnishment was enforceable. The Supreme Court reversed, holding (1) a support order must be treated as a garnishment, and therefore creditor judgment garnishments may be imposed only to the extent support garnishments do not exceed the general twenty-five percent limit; and (2) because Bruce's support garnishment was approximately forty-two percent of his disposable earnings the district court erred in enforcing additional garnishment for the property settlement debt to Tanya. View "Knell v. Knell" on Justia Law

Posted in: Family Law

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The Supreme Court affirmed the judgment of the district court dismissing a petition filed under the Post-Conviction Determination of Factual Innocence Act for failing to identify newly discovered evidence and for making conclusory claims, holding that the district court properly dismissed Appellant's petition on its initial review. The district court summarily denied Appellant's actual innocence petition for failing to cite newly discovered evidence that would clearly establish his factual innocence and for making irrelevant and conclusory allegations. The Supreme Court affirmed, holding (1) the district court did not err in finding that Appellant did not present newly discovered evidence his post-conviction petition for determination of factual innocence; and (2) the district court's denial was not premature in light of the district court's refusal to grant Appellant an evidentiary hearing. View "Sullivan v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the order of the district court dismissing Appellant's complaint against the Wyoming Department of Corrections (WDOC) asking that the WDOC recognize Humanism as a religion, holding that the district court correctly dismissed Appellant's complaint as moot. Appellant, an inmate in the custody of the WDOC, brought this complaint under 42 U.S.C. 1983 seeking declaratory and injunctive relief and seeking money damages against the WDOC's director and its deputy administrator in their individual capacities. After Appellant filed his complaint, the WDOC officially recognized Humanism as a religion. Thereafter, the district court dismissed Appellant's complaint and denied Appellant's motion for attorney fees. The Supreme Court affirmed, holding (1) the voluntary cessation exception to the mootness doctrine has not been adopted in Wyoming; (2) Defendants were entitled to qualified immunity; and (3) Appellant was not a "prevailing party" under 42 U.S.C. 1988. View "Guy v. Lampert" on Justia Law

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The Supreme Court reversed the judgment of the district court granting Father's petition to modify custody and awarding Father primary physical custody of the parties' four-year-old son, holding that the district court abused its discretion when it ignored certain material factors in determining that modification of the original order was warranted. After a trial, the district court found that Mother's move from Buffalo, Wyoming to Plains, Montana constituted a material change in circumstances and that it was in the child's best interests to grant Father primary physical custody. The Supreme Court reversed, holding (1) the district court did not abuse its discretion determining that a material change in circumstances justified reopening its prior custody order; but (2) the district court abused its discretion when it determined that transferring custody to Father was in the child's best interests. View "Ianelli v. Camino" on Justia Law

Posted in: Family Law

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The Supreme Court reversed the order of the district court partitioning a vacant lot that Rhonda Gallagher and Curtis Townsend owned as joint tenants with rights of survivorship, holding that the district court improperly partitioned the property. Gallagher filed suit seeking partition of the lot she and Townsend owned as joint tenants with rights of survivorship. The district court ordered the sale of the lot if neither party elected to purchase the other party's share and that equitable division of the proceeds was proper. After valuing the property at $33,500, the court ordered that Townsend was entitled to the first $25,017.20 in proceeds from the sale of the property. The Supreme Court reversed, holding (1) the district court properly concluded that each party owned an undivided, one-half interest in the property; (2) after deciding the parties' interests, the district court erred by exercising its equitable powers to divest Gallagher of her interest in the property; and (3) the district court clearly erred in finding that Townsend paid $4,251.53 in property taxes. View "Gallagher v. Townsend" on Justia Law

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The Supreme Court affirmed the judgment of the district court dismissing Finley Resources, Inc.'s complaint against EP Energy E&P Company on the grounds that the forum-selection clause contained in the contract between the parties required Finley to file its suit in Texas, holding that the district court did not abuse its discretion in declining to exercise jurisdiction based on the forum-selection clause. On appeal, Finley argued that the district court abused its discretion in dismissing Finley's lawsuit because the declaratory judgment, quiet title, and adverse possession claims did not arise from the parties' contract and, even if the equitable causes of action arose from the contract, the Texas courts lacked subject matter jurisdiction to consider the claims. The Supreme Court disagreed, holding (1) Finley's equitable claims were matters in connection with the contract and were subject to the forum-selection clause; and (2) Finley's claims will necessarily be resolved by the Texas court's determination of its contractual rights. View "Finley Resources, Inc. v. EP Energy E&P Co." on Justia Law

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The Supreme Court affirmed Defendant's convictions of one count each of felony stalking and burglary, holding that Defendant was not entitled to relief on any of his allegations of error. Specifically, the Court held (1) Defendant was not prejudiced when his counsel failed to file a motion to suppress statements Defendant made without receiving a Miranda warning; (2) review of Defendant's claim that the district court erred in failing to suppress Defendant's statements made without a Miranda warning was precluded; (3) the district court did not abuse its discretion in admitting body camera footage of Defendant's traffic stop; and (4) Defendant's convictions were supported by sufficient evidence. View "Bittleston v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court dismissing Appellant's petition seeking exoneration under the newly enacted Post-Conviction Determination of Factual Innocence Act, Wyo. Stat. Ann. 7-12-401 through 407, holding that the district court did not err when it dismissed the petition because it lacked documentation of any newly discovered evidence that would establish Appellant's innocence. Appellant, who was convicted for first degree murder and assault and battery, filed his petition for exoneration thirty-eight years after his convictions. The district court dismissed the petition without prejudice because it lacked any documentation of newly discovered evidence that would establish Appellant's innocence. The Supreme Court affirmed, holding that Appellant failed to comply with the statutory requirements of the Act, and therefore, the district court did not err when it dismissed the petition. View "Parkhurst v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the district court's grant of summary judgment to Employer on Employee's retaliatory discharge claim, holding that summary judgment was proper under the circumstances of this case. In support of Employee's claim for retaliatory constructive discharge Employee alleged that Employer retaliated against him for his submitting a report on elder abuse of a resident that was required by statute. The district court granted Employer's motion for summary judgment. The Supreme Court affirmed, holding that the evidence Employee submitted in response to Employer's motion for summary judgment failed to create a disputed issue of material fact that would make his prima facie claim a triable issue. View "Kaufman v. Rural Health Development, Inc." on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Father's complaint to modify custody claiming a material change in circumstances, holding that the district court did not abuse its discretion in determining that no material change of circumstances occurred. In 2014, Father filed a petition to establish paternity, custody and support with regard to a child born in 2013. Mother and Father filed a stipulated agreement establishing joint legal custody with Mother having primary residential custody. The stipulation contained a visitation schedule and child support calculations. In 2017, Father filed a complaint to modify the order on custody and visitation. After an evidentiary hearing, the district court concluded that no material change in circumstances occurred since the entry of the order approving stipulation on paternity, custody and visitation. The Supreme Court affirmed, holding that the district court did not abuse its discretion. View "Smith v. Kelly" on Justia Law

Posted in: Family Law