Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court summarily affirmed the judgment of the district court in this marriage dissolution action, holding that the district court did not err in granting Wife's motion to alter or amend judgment pursuant to Wyo. R. Civ. P. 59, and this Court declines to impose sanctions under Wyo. R. App. P. 10.05.After a bench trial the district court entered a decree of divorce dividing the martial assets and ordering Wife to make a lump sum equalization payment to Husband subject to statutory interest. Wife moved to alter or amend the judgment requesting a payment plan without interest for the equalization payment. The district court granted the motion. The Supreme Court summarily affirmed, holding that Husband's brief on appeal was deficient in several respects and lacked cogent argument. View "McInerney v. Kramer" on Justia Law

The Supreme Court affirmed the decision of the Board of Equalization affirming the Wyoming Departments of Audit and Revenue's mineral tax audit assessments of Chesapeake Operating, LLC's oil and gas production, holding that the State Board of Equalization did not misinterpret Wyo. Stat. Ann. 39-14-203(b)(iv) when it found that Chesapeake's field facilities did not qualify as processing facilities.On appeal, Chesapeake argued that the Board erred in concluding that Chesapeake's facilities qualified as processing facilities under the mineral tax statutes and that the proper point of valuation for its gas production was at the custody transfer meters. The district court certified the case directly to the Supreme Court, which affirmed, holding that the Board correctly interpreted and applied Wyo. Stat. Ann. 39-14-201(a)(xviii) when it found that the seven facilities at issue were not processing facilities. View "Chesapeake Operating, LLC v. State, Dep't of Revenue" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence under Wyo. R. Crim. P. 35(a), holding that the district court did not err in concluding that Defendant's motion was barred by res judicata.Defendant was convicted of two counts of aggravated vehicular homicide and sentenced to twelve to twenty years in prison on each count, to be served consecutively. After unsuccessfully moving in 2015 to correct an illegal sentence, in 2022 Defendant filed the current motion to correct an illegal sentence, arguing that his consecutive sentences were illegal because they exceeded the twenty-year statutory maximum sentence for aggravated vehicular homicide. The district court denied the motion on res judicata grounds. The Supreme Court affirmed, holding that because Defendant already raised and litigated the claim presented in his current motion, the district court did not err in denying the Rule 35(a) motion on res judicata grounds. View "Tucker v. State" on Justia Law

The Supreme Court reversed the judgment of the district court granting Wife's motion filed under Wyo. R. Civ. P. 60 seeking to set aside a stipulated final decree of divorce due to inadvertence or mistake, holding that the stipulated decree was ambiguous, and the record was insufficient to support the district court's interpretation.After the stipulated decree was entered in this case Husband refinanced the marital home. Wife believed she was entitled to half of the net equity in the home at the completion of the refinance, but Husband argued that she was only entitled to half the net proceeds if the house was sold. The district court granted Wife's Rule 60 motion determining that the stipulated decree unambiguously required Husband to pay Wife half the equity in the property from the refinance or sale of the home. The court entered an order requiring that any equity recognized through sale or refinance of the home was to be equally divided between the two parties. The Supreme Court reversed and remanded the case, holding (1) the stipulated decree was ambiguous as to whether Husband was required to provide Wife half the net proceeds in the event of refinance; and (2) the record did not contain sufficient evidence to clarify the stipulated decree under Rule 60(a). View "Van Vlack v. Van Vlack" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion in his criminal case for the return of property seized by law enforcement during the underlying criminal investigation, holding that remand was required.Defendant pleaded guilty to aggravated assault and battery. Several months after he was sentenced Defendant filed a motion requesting suppression of items used as evidence in his case. The district court ruled that it did not have jurisdiction over Defendant's motion in the criminal case because a post-conviction motion for return of property is a civil matter. The Supreme Court reversed, holding that the district court erred in declaring that it did not have jurisdiction to consider Defendant's motion for return of his property, nor did it have the legal authority to order return of the property because the motion was authorized by Wyo. R. Crim. P. 41(d), and the court should have received evidence to determine whether Defendant was entitled to return of the property. View "Bunten v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence, holding that the district court did not err in ruling that res judicata barred Defendant's motion to correct an illegal sentence.Defendant was convicted of second-degree abuse of a minor and soliciting a minor to engage in sexual relations and sentenced to twenty years as to the sexual abuse conviction and to four to five years on the solicitation conviction, to be served consecutively. Defendant later filed a pro se motion to correct an illegal sentence, arguing that the acts underlying his conviction were one continuous act and that his consecutive sentences violated double jeopardy protections. The district court denied relief ruling that res judicata barred the motion. The Supreme Court affirmed, holding (1) a motion to correct an illegal sentence can be subject to res judicata; and (2) the interests of res judictata in finality and avoiding repetitive litigation were served in this case. View "Peterson v. State" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of the State in this action brought by Plaintiffs claiming that a contract health care provider for the State at the Wyoming Medium Correctional Institution (prison) acted negligently when she injected Appellants with the Janssen COVID-19 vaccine, holding that the State was immune from suit and liability.Plaintiffs, inmates at the prison, brought this action claiming that they were wrongfully injected with the Janssen COVID-19 vaccine because the consent forms Plaintiffs signed mentioned only the Moderna and Pfizer COVID-19 vaccines. The district court declined to allow Appellants additional time for limited discovery and granted summary judgment in favor of the State, finding that State had immunity. The Supreme Court affirmed, holding (1) the district court did not err when it declined to allow Plaintiffs limited discovery; and (2) the federal Public Readiness and Emergency Preparedness Act shielded the State from suit and liability in this case. View "Bird v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment for Defendants and denying relief in this class action, holding that the district court did not err.In 2014, over two-thirds of the members of the Try County Telephone Association, Inc., a Wyoming cooperative utility providing telecommunication services on a non-profit basis, voted to sell the Cooperative, including its for-profit subsidiaries, to entities owned by Neil Schlenker. Schlenker converted the Cooperative into a for-profit corporation (TCT). After the sale, Class Representatives filed a class action lawsuit against TCT, Schlenker and his entities, and others, alleging fraud conversion and other claims and requesting that the sale be set aside. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding that the district court did nor err in granting summary judgment on all claims. View "Campbell v. Davidson" on Justia Law

The Supreme Court reversed in part and affirmed in part the judgment of the district court in favor of Baldwin, Crocker & Rudd, P.C. and Kelly Rudd (collectively, BCR) in this action brought by the Northern Arapaho Tribe and the Wind River Hotel & Casino (collectively, the Tribe), holding that the district court's order imposing sanctions on the Tribe was erroneous.The Tribe brought this action seeking injunctions for the return of tribal funds and documents, an accounting, and damages for conversion and civil theft. The district court granted summary judgment for BCR on the accounting and injunctions claims and, after a jury trial, entered final judgment on the conversion and civil theft claim. The Tribe appealed, arguing, among other things, that the district court erred by awarding sanctions under Wyo. R. Civ. P. 11. The Supreme Court reversed in part, holding that (1) the district court erred in imposing sanctions because BCR failed to comply with the procedural requirements of Rule 11; (2) the district court did not err when it granted summary judgment for BCR on the Tribe's accounting claim; and (3) the Tribe failed to show the verdict would have been more favorable if racially charged evidence had not been admitted. View "Northern Arapaho Tribe v. Baldwin, Crocker & Rudd, P.C." on Justia Law

The Supreme Court affirmed the decision of the district court denying Appellant's motion to correct an illegal sentence, holding that the district court correctly concluded that Appellant was not entitled to credit for time spent on probation when he was resentenced in a probation revocation proceeding.Defendant admitted to the State's allegations of probation violations, and his probation was revoked and sentence reinstated. Defendant filed a motion to correct an illegal sentence, claiming that he was entitled to credit for time spent on supervised probation, inclusive of inpatient substance abuse treatment and participation in Treatment Court. The district court denied the motion. Defendant subsequently moved both a second and third time to correct an illegal sentence, without success. Defendant appealed the district court order denying his first request to correct an illegal sentence. The Supreme Court affirmed, holding that the district court properly denied the motion. View "Stevenson v. State" on Justia Law