Justia Wyoming Supreme Court Opinion Summaries

In a case certified by the United States District Court for the District of Wyoming, the Supreme Court of Wyoming was tasked with two questions regarding the duty of care owed by law enforcement officers to suspects while conducting an investigation.The first question asked whether a law enforcement officer acting within the scope of their duties owed a duty of care to the suspect(s) in a criminal investigation to conduct that investigation in a non-negligent manner. The court affirmed that law enforcement officers indeed owe such a duty, consistent with existing precedent.The second question asked whether, if a duty of care is owed, the law enforcement officer is entitled to assert qualified immunity under Wyoming law. The court affirmed that law enforcement officers are entitled to assert qualified immunity. Qualified immunity protects officers who act in good faith and whose actions are reasonable under the circumstances, and it serves important policy purposes, such as protecting law enforcement from the risk of being liable for mistakes made in the performance of their duties.The specific facts of the case involved a law enforcement officer who had received a tip about a suspected marijuana growing operation and subsequently initiated an investigation. The suspect, Deborah Palm-Egle, later filed a civil action against the officer and other parties, alleging a variety of tort claims. View "Palm-Egle v. Briggs" on Justia Law

During her employment as an administrative assistant, Judy Valencia suffered a right knee injury, which was covered by workers' compensation. Following the knee injury, she altered her gait and started experiencing pain in her left foot, ankle, and hammertoe. She sought workers' compensation benefits for these injuries, contending that they were causally related to her compensable right knee injury. However, the Wyoming Department of Workforce Services, Workers' Compensation Division denied the benefits, stating that the left foot, ankle, and hammertoe injuries were not related to the right knee injury. The Wyoming Medical Commission upheld the denial, and the district court affirmed the Commission's decision.In the Supreme Court, State of Wyoming, Valencia argued that her left foot, ankle, and hammertoe injuries either constituted a second compensable injury caused by her right knee injury or materially aggravated her preexisting left foot conditions. The court upheld the lower courts' decisions, finding that Valencia failed to meet her burden of proving either claim. The court noted that Valencia's treating physicians did not opine that her right knee injury or altered gait materially aggravated her preexisting left foot conditions. Additionally, the court found that an independent medical examiner's opinion, which stated that the right knee injury did not cause any temporary exacerbations or permanent material aggravation of Valencia's preexisting left foot conditions, was supported by substantial evidence. Therefore, the court affirmed the denial of workers' compensation benefits for Valencia's left foot, ankle, and hammertoe injuries. View "Valencia v. State of Wyoming, Ex Rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The case involves a dispute between the Teton County Assessor and Aspen S, LLC along with the Kelvin and Nancy Stirn Trusts. The landowners in Teton County contested the reclassification of their property from "agricultural" to "non-agricultural" by the Teton County Assessor. The Teton County Board of Equalization held a contested case hearing and found that the County Assessor's removal of the agricultural classification was incorrect. The County Assessor then appealed this decision to the State Board of Equalization.The State Board of Equalization consolidated the cases and sided with the County Assessor, stating that the County Board of Equalization had rejected the Assessor's determination without sufficient explanation. However, the State Board also assessed all the evidence independently and found that the taxpayers had not met their burden of proof. The landowners then sought judicial review of the agency's action in the district court, a portion of whose decision was adverse to the Teton County Assessor who now seeks further judicial review in the Supreme Court of Wyoming.The Supreme Court of Wyoming reversed and remanded the case, finding that the County Board of Equalization's decision lacked necessary findings of fact and conclusions of law as required by the Wyoming Administrative Procedure Act (WAPA). This lack of necessary findings and conclusions rendered the record insufficient for judicial review, causing the County Board of Equalization to act arbitrarily and capriciously. The case was remanded to the district court, with instructions to remand to the State Board of Equalization, which was instructed to remand to the Teton County Board of Equalization for findings and conclusions as required by WAPA. View "Teton County Assessor v. Aspen S, Llc" on Justia Law

The case involves a mother appealing against a juvenile court's ruling that she neglected her infant son, AE. The infant was born prematurely and consistently underweight. Despite numerous hospitalizations and health professional instructions, the child's weight did not significantly increase while under the parents' care. However, the child showed substantial weight gain while hospitalized. The State filed a petition alleging that the parents neglected AE by failing to provide adequate care necessary for the child's well-being. The juvenile court ruled in favor of the State concerning the mother, but not the father, due to insufficient evidence against him.The Supreme Court of Wyoming affirmed the lower court's decision. The court found that the evidence of the child's ability to gain weight in a hospital setting versus his home was enough to support the neglect adjudication against the mother. The court stressed that although the mother followed medical instructions and took AE to medical appointments, the child's failure to thrive at home pointed to neglect. This case demonstrates that the courts assess neglect based on the child's well-being and not necessarily on the intent or efforts of the parents. View "In the Interest of A. E. v. The State of Wyoming" on Justia Law

In the Supreme Court of Wyoming, a case involving minor children was brought forward by their parents, MK and JP-W, against the State of Wyoming. The parents challenged the juvenile court's decision to change the permanency plan for their five children from family reunification to adoption or guardianship. The parents had separated, and the children were taken into protective custody after the father was arrested for aggravated assault.The court affirmed the juvenile court's decision, stating that the Department of Family Services (DFS) had made reasonable efforts to reunify the family without success and that reunification was no longer in the children's best interest. The court found that both parents had significant obstacles to providing suitable environments for the children. The father struggled to obtain appropriate housing and had inconsistent communication with the DFS, while the mother had issues related to domestic violence and failed to complete necessary paperwork concerning past abuse allegations.Additionally, the court rejected the mother's argument that the DFS had violated her due process rights by employing the Interstate Compact on the Placement of Children (ICPC) mechanism to assess her fitness for placement. The court also rejected the claim that the Guardian ad Litem (GAL) should not have been allowed to prove the grounds for the permanency change. Finally, the court found no violation of Mother's due process rights in admitting evidence and witness testimony by the GAL that was not disclosed until shortly before the permanency hearing. The court determined that the parents had been given adequate opportunity to cross-examine witnesses, call their own witnesses, and present their case for reunification. View "MK v. The State of Wyoming" on Justia Law

In Wyoming, Jerry Peterson brought a case against the Laramie City Council, alleging that the council violated the Wyoming Public Meetings Act by holding its meetings remotely during and after the COVID-19 pandemic. Peterson argued that this remote format presented a barrier to attendance at the council meetings, violating a section of the Act that states a member of the public should not be required to fulfill any condition precedent to their attendance. The District Court dismissed the case on the grounds of laches, asserting that Peterson had delayed unreasonably in filing the suit. However, the Supreme Court of Wyoming reversed this decision and remanded the case back to the lower court. The Supreme Court found that the District Court had incorrectly determined Peterson's claims all accrued at the same time and that it had improperly taken judicial notice of the City Council's evidence. The Supreme Court also concluded that the District Court had made an erroneous conclusory determination that the City Council would be prejudiced by Peterson’s delay in bringing his action. View "Peterson v. Laramie City Council" on Justia Law

In the State of Wyoming, Jonathon Tyson Blair, representing himself, appealed the denial of his motion for sentence reduction by the District Court of Sweetwater County. Blair had been sentenced to a term of eight to ten years and requested a reduction to a term of five to ten years. He argued that he had taken steps to improve himself while incarcerated and that he needed the sentence reduction to prevent his welding certification from expiring, so he could financially support his family upon release.The Supreme Court of Wyoming affirmed the decision of the lower court, stating that the denial of the motion for sentence reduction did not constitute an abuse of discretion. The court highlighted that the sentencing judge is in the best position to determine if a sentence modification is appropriate and can accept or reject information submitted in support of a sentence reduction at their discretion. The court found that there was a rational basis from which the lower court could draw its conclusion and that the original sentence imposed on Blair remained appropriate. The court also dismissed Blair's allegations of bias and illegal sentencing, stating that these issues were not raised in his motion for sentence reduction and could not be raised for the first time on appeal. Furthermore, the court discarded Blair's claim that his pre-sentencing time served was not credited to his sentence, stating that this was a matter for relief under a different rule and that the issue had already been addressed and rejected in prior proceedings. View "Blair v. The State of Wyoming" on Justia Law

The case revolves around the defendant, Daniel A. Chace, who appealed the denial of his motion to suppress evidence obtained through a search warrant executed after 10:00 p.m. The incident began when law enforcement stopped a vehicle for a traffic violation, driven by Mr. Chace’s brother. A search of the vehicle following a K-9 unit’s drug alert resulted in the discovery of methamphetamine and paraphernalia. That evening, the officers requested a search warrant for the driver's residence, where Mr. Chace was temporarily staying. The search warrant was executed shortly after 10:00 p.m., leading to the discovery of more drugs and paraphernalia in Mr. Chace's backpack.Mr. Chace argued that the evidence should be suppressed because the search of the residence violated Rule 41 of Wyoming's Rules of Criminal Procedure, which restricts the execution of search warrants to between 6:00 a.m. and 10:00 p.m., unless express authorization for a different time is provided based on good cause. The Supreme Court of Wyoming, however, affirmed the district court's decision, concluding that the nighttime search did not prejudice Mr. Chace and that law enforcement did not intentionally and deliberately disregard the limits in Rule 41(e)(1). The court maintained that a violation of Rule 41 alone does not necessarily equate to a Fourth Amendment violation and does not always invoke the application of the exclusionary rule. View "Chace v. The State of Wyoming" on Justia Law

In the Supreme Court of Wyoming, an appeal by Ronald Pinther, a former insurance agent, was dismissed. Pinther had worked for American National Property and Casualty Insurance Company (ANPAC) and American National Insurance Company (ANICO). He filed a lawsuit against ANPAC, ANICO, and another agent, Philip Maggard, claiming breach of contract, breach of good faith and fair dealing, fraudulent inducement, promissory estoppel, civil conspiracy, and age discrimination. The district court granted summary judgment in favor of ANPAC and Mr. Maggard. On appeal, the Supreme Court held that the district court had not erred in its decision. The court found that Mr. Pinther's breach of contract claim against ANPAC was governed by the Post-Termination Compensation Schedule outlined in the agent agreement. The court further held that Mr. Pinther's claim of a breach of an implied duty of good faith and fair dealing could not be maintained given the at-will nature of the agency contract. The court also dismissed Mr. Pinther's fraudulent inducement claim against ANPAC, noting that the recruiting brochure did not govern his agreement with ANPAC. The court further held that Mr. Pinther's claim for tortious interference with a contract against Mr. Maggard could not be maintained as the actions of Mr. Maggard, as an agent of ANPAC, were imputed to ANPAC. Lastly, the court held that Mr. Pinther's civil conspiracy claims against ANPAC and Mr. Maggard failed as the underlying tort claims did not survive summary judgment. View "Pinther v. American National Property and Casualty Insurance Company" on Justia Law

The Supreme Court of Wyoming reversed a lower court's decision, finding that David Spurlock's lawsuit to remove the Wyoming Trust Company as the trustee of the C.E. Spurlock Revocable Trust did not trigger the trust's no-contest clause, which would have resulted in his disinheritance. The court determined that while the trust's no-contest clause expressed a desire to avoid litigation, it did not prohibit all litigation. The court noted that other provisions in the trust specifically authorized a beneficiary to bring certain forms of litigation, and that Spurlock's action was not a challenge to the trust or an attempt to impair the trust's function or operations. The court found that the lawsuit was intended to enforce the trust's provisions related to accountings and instructions for dividing assets and did not seek damages from trust assets or seek to change or delay the asset distribution. Therefore, Spurlock's lawsuit did not violate the no-contest clause. The case was remanded with instructions to enter summary judgment in favor of Spurlock on the trustee's counterclaim. View "Spurlock v. Wyoming Trust Company" on Justia Law