Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the district court's grant of summary judgment against Steven Johnson and his legal entities (collectively, Appellants) on Johnson's legal malpractice claims against Danielle M. Mathey and Mathey Law Office, P.C. (collectively, Appellees), holding that Appellees were entitled to judgment as a matter of law.Appellants sued Appellees alleging legal malpractice regarding Mathey's representation of Johnson on various matters. Because Appellants did not designate an expert witness or present any competent evidence establishing the legal elements of their legal malpractice claims the district court granted summary judgment for Appeellees, finding that Appellants failed to establish through expert testimony or other competent evidence a genuine issue of material fact on the elements of their claims. The Supreme Court affirmed, holding that, under the facts of this case, the district court properly granted summary judgment in favor of Appellees. View "Johnson v. Mathey" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellants' joint motion to suppress more than 300 pounds of marijuana law enforcement discovered during a traffic stop on Interstate 80 in Wyoming, holding that the district court did not err when it denied Appellants' motion to suppress evidence.Appellants - Cristian Ramirez and Hector Zapien-Galvan - were pulled over by state troopers for an expired registration. Appellants refused to consent to a search of the car, after which a certified canine alerted to packages containing 320.6 pounds of marijuana. Appellants moved to suppress the evidence, arguing that the officer's conduct in pursuing their vehicle without reasonable suspicion negated the subsequent probable cause for the search. The district court denied the motion. The Supreme Court affirmed, holding that the district court properly denied Appellants' motion to suppress because the underlying traffic stop was both objectively justified and reasonable at its inception and did not violate Wyo. Const. art. I, 4 or the Fourth Amendment. View "Zapien-Galvan v. State" on Justia Law

The Supreme Court affirmed the order of the district court modifying Father's child support, holding that Mother was not entitled to relief on her allegations of error.On appeal, Mother argued that the district court abused its discretion when it calculated Father's net monthly income without first obtaining sufficient financial information and by calculating her net monthly income contrary to the evidence on the record. The Supreme Court affirmed, holding that the district court (1) obtained sufficient financial information to calculate Father's net monthly income; and (2) did not abuse its discretion in calculating Mother's net monthly income. View "Corbitt v. Davidson" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to withdraw his pleas of no contest to voluntary manslaughter, attempted voluntary manslaughter, two counts of aggravated robbery, and four counts of interference with a peace officer, holding that the district court did not abuse its discretion when it denied Defendant's motion to withdraw his no contest pleas.Defendant pleaded no contest to the charges against him pursuant to a plea agreement with the State. Before he was sentenced, Defendant moved to withdraw his pleas, arguing that his right to a speedy trial was violated and that defense counsel did not provide effective assistance of counsel. The district court denied the motion and sentenced Defendant according to the plea agreement. That Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant's motion to withdraw his pleas. View "McHenry v. State" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of Defendant and dismissing Plaintiffs' complaint seeking to recover damages for the emotional distress they allegedly suffered when their dogs died after becoming entangled in Defendant's snares, holding that there was no error.In his motion for summary judgment, Defendant asserted that Plaintiffs' emotional distress were not compensable because dogs are considered property. The district court granted the motion. The Supreme Court affirmed, holding (1) under Wyoming law, dogs are property; (2) while Plaintiffs might be entitled to emotional damages for their own injuries, the impact rule did not extend their recovery to emotional damages caused by the dogs' death; and (3) Plaintiffs' argument that recovery for emotional distress damages should be allowed when animate property is negligently harmed is best made to the legislature. View "Cardenas v. Swanson" on Justia Law

The Supreme Court affirmed Defendant's conviction, entered upon his conditional plea of guilty, of felony possession of methamphetamine, holding that the district court did not err in denying Defendant's motion to suppress evidence obtained from his vehicle after law enforcement stopped him for failing properly to signal a left turn.On appeal, Defendant challenged the district court's interpretation of the applicable statute, Wyo. Stat. Ann. 31-5-217, arguing that he complied with the statute and that the officer lacked reasonable suspicion to stop him. The Supreme Court affirmed, holding that Defendant's argument that this Court should interpret the statute to require no more than a turn be made safely ignored the rules of statutory interpretation. View "Anderson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court awarding Mother primary custody of the couple's two children and dividing the marital property, holding that the district court did not err or abuse its discretion.Father filed for divorce, and Mother counterclaimed for divorce. After a trial, the district court granted the parties a decree, awarded Mother primary custody of the parties' two children, ordered Father to pay Mother monthly child support, and divided the marital property. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by admitting the opinion testimony and report of one of Mother's witnesses because Mother's failure to designate that witness as an expert witness was harmless; and (2) did not abuse its discretion by granting Mother primary custody or in its division of the marital property. View "Dutka v. Dutka" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for possession and delivery of methamphetamine, holding that the district court did not err in denying Defendant's motion for a sentence reduction pursuant to Wyo. R. Crim. P. 35(b).Defendant was charged with five felony offenses related to possession and delivery of a controlled substance and, pursuant to a plea agreement, pled guilty to one count of possession and one count of delivery of methamphetamine. The district court sentenced Defendant to five to seven years on the possession charge and a consecutive sentence of ten to fifteen years on the delivery charge. Defendant later filed her motion for sentence reduction, which the district court denied. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it did not elaborate on its reasons for denying Defendant's motion for sentence reduction and that there was no other error in the proceedings. View "Hurtado v. State" on Justia Law

The Supreme Court reversed the order of the district court granting Mother's motion for default and making final a temporary child support order from 2018, holding that the district court erred.In this appeal, Father challenged a district court order granting Mother's motion for default and making final a 2018 temporary child support order, arguing, among other things, that the district court violated his right to due process by granting Motion's motion for default before the closing of his twenty-day response window under Wyo. R. Civ. P. 6(c)(2). The Supreme Court reversed, holding (1) Father timely filed his notice of appeal, and therefore, this Court had jurisdiction; (2) the district court violated Father's right to due process by granting Mother's motion before Father's opportunity to respond expired; and (3) the district court abused its discretion by making the 2018 temporary child support order the final order without obtaining sufficient financial information under Wyo. Stat. Ann. 20-2-308. View "Tucker v. Tucker" on Justia Law

The Supreme Court dismissed for lack of jurisdiction this appeal from the order of the district court dismissing Appellant's appeal of the Natrona County Board of Commissioners' decision denying Appellant's application to transfer a liquor license to him, holding that the district court did not have subject matter jurisdiction.In a separate lawsuit, the district court ordered the CC Cowboys, Inc.'s (CCCI) liquor license be transferred to Appellant. Appellant applied to the Board for the transfer of CCCI's liquor license, but the Board denied the transfer on the grounds that the "transfer will adversely affect the welfare of the people residing in the vicinity of the proposed license address." Appellant appealed to the district court, which found that it lacked jurisdiction to review the proceedings. The Supreme Court affirmed, holding that the district court correctly determined that it was without jurisdiction. View "Elliott v. Natrona County Bd. of Commissioners" on Justia Law