Justia Wyoming Supreme Court Opinion Summaries

In the Supreme Court of the State of Wyoming, the appellant, Rachel E. Bennett, appealed a district court decision that held her in contempt of court for failing to adhere to several provisions of a divorce decree. The decree involved her ex-spouse, Matthew J. Bennett, and outlined certain responsibilities concerning their two minor children. These responsibilities included equally sharing uninsured medical expenses for their children, following all medical directives regarding the children's health, and consulting each other before making any non-emergency decisions about the children's health, education, or welfare.The district court found Rachel in contempt for failing to pay her half of the uninsured medical bills, not adhering to medical directives for their oldest child, and reengaging the children in counseling without seeking Matthew's advice or consent. The Supreme Court of Wyoming affirmed the district court's decision, finding no error in the lower court's judgment that Rachel had willfully disobeyed the provisions of the decree. They held that the district court did not abuse its discretion in its findings, and that it could reasonably conclude as it did based on the testimony presented by both parties. View "Bennett v. Bennett" on Justia Law

In the State of Wyoming, the Supreme Court examined a dispute between Tony R. Testolin, Tim Karlberg, and Thirty-One Bar Ranch Company about the use of an access easement. The defendants (Testolin and Karlberg) owned an easement that passed over a portion of Thirty-One Bar's property. Thirty-One Bar challenged the validity of the easement and its use. While the district court affirmed the validity of the easement, it restricted how the defendants could use it. The court ruled that the defendants could not use the easement to allow a commercial hunting outfitter access to their property, which the defendants appealed.The Supreme Court of Wyoming reversed the lower court's decision. It ruled that the easement's language did not restrict the defendants from using it to allow a hunting outfitter access to their property. The court also ruled that Thirty-One Bar did not meet its burden of proving that such use of the easement materially increased the burden on their property. Thus, the lower court erred in declaring this use of the easement as impermissible. The court emphasized that an easement may be used for any reasonable use of the dominant estate, provided that use does not materially increase the burden on the servient estate. View "Testolinv. Thirty-One Bar Ranch Company" on Justia Law

In this case, the Supreme Court of Wyoming affirmed the lower court's decision to grant Mrs. Tokowitz the right to a spousal election against her late husband's will. The late Mr. Tokowitz had left his estate to a revocable trust and made no provision for Mrs. Tokowitz in his will. The court held that Mrs. Tokowitz was not deprived of her spousal election right simply because her husband's property was transferred to his trust through a pour-over will. The court reasoned that property transferred by a pour-over will is part of the decedent's probate estate until the will is probated. Only after probate does it pass in accordance with section 2-6-103 to the trust to be distributed by the trust terms. The court also found that Mr. Tokowitz was domiciled in Wyoming at the time of his death, as evidenced by his will, making Mrs. Tokowitz eligible for the spousal election under Wyoming law. The court declined to rule on Mrs. Tokowitz's rights as a beneficiary under the trust, stating that issues relating to the trust were outside of its jurisdiction. View "In the Matter of the Estate of Tokowitz v. Tokowi" on Justia Law

In this case heard by the Supreme Court of the State of Wyoming, the plaintiff, Scherri Hacker, made a conversion claim against Hacker Oil, Inc., which had paid premiums on a whole life insurance policy on her husband, James Hacker. The policy was executed as a split-dollar arrangement, with the intention that upon Mr. Hacker's death, Hacker Oil would be reimbursed for the paid premiums, and the remaining death benefits would be distributed to Mrs. Hacker. After Mr. Hacker's death, Hacker Oil received $125,000 and half the interest accrued under the policy, which exceeded the $55,048 it had remitted in premium payments.The defendant, Hacker Oil, appealed the district court's decision, arguing that Mrs. Hacker had failed to mitigate her damages by withholding her signature from a letter agreement and by asserting a conversion claim against Hacker Oil. The court, however, upheld the district court's ruling, finding that Mrs. Hacker did not have a duty to mitigate her damages. The court determined that Mrs. Hacker's failure to sign the letter agreement prior to Hacker Oil's signing and submission of a claim to the insurance company did not constitute a failure to mitigate damages. The court further concluded that once Hacker Oil committed the conversion, Mrs. Hacker rightfully brought a claim and asserted her rights. Thus, the Supreme Court of the State of Wyoming affirmed the district court's decision, holding that Hacker Oil had wrongfully converted $70,372.68, the difference between the amount it received and the amount it was entitled to receive. View "Hacker Oil, Inc. v. Hacker" on Justia Law

In Wyoming, Remi Larsen was facing a misdemeanor charge for possession of a controlled substance. Larsen moved to suppress evidence obtained during a warrantless search of her apartment. The trial court granted Larsen's motion, ruling that she did not voluntarily consent to the search. The State appealed this decision, resulting in the district court reversing the trial court's order. On further appeal, the Supreme Court of Wyoming held that the district court abused its discretion when it initially granted the State's petition for an interlocutory writ of review. The Supreme Court explained that the district court should only grant such a review in "rare and unusual" cases that present questions of first impression, constitutional magnitude, and great public import. The court found that Larsen's case did not meet these criteria. The court's order was reversed, and the lower court was directed to reinstate the original suppression order. View "Larsen v. State" on Justia Law

In the case before the Supreme Court of Wyoming, Todd Andrew Domenico and Josie Daniel, formerly married, were in a dispute over custody of their two children. The couple divorced in 2018, with the court awarding joint legal custody to both parents and primary physical custody to the father. In 2020, the mother filed for a modification of the decree, requesting primary physical custody of the children. The district court maintained primary physical custody with the father and increased the mother's visitation rights. Both parents appealed this decision.The Supreme Court found that the district court abused its discretion in several aspects. First, it erred in denying a psychological evaluation of the mother and prohibiting inquiry into her mental health. The mother's mental health was directly relevant to determining the best interest of the children. Second, the court's factual conclusions were insufficient to support its visitation determinations. The findings did not provide enough specifics or detail to clarify the reasoning behind the decisions, particularly regarding the extension of the mother's summer visitation and the removal of the requirement for the mother to provide qualified caregivers for the severely autistic child. Third, the court erred in failing to designate one parent as the final decision-maker on issues of the children's welfare, particularly medical decisions. The court's refusal to resolve the parents' impasse over medical decision-making was harmful to the children. Lastly, the district court abused its discretion in refusing to consider allegations of the mother's psychological abuse of one child after the evidence had closed.The Supreme Court affirmed the district court's decision to not modify physical custody of the children, and it did not exceed its jurisdiction when it prohibited the mother from obtaining a psychological evaluation of the children. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Daniel v. Domenico" on Justia Law

In this case, appellant Ismael Ruiz sought to appeal the dismissal of his motion for a sentence reduction by the District Court of Sweetwater County, Wyoming, arguing that the court had erred in ruling it did not have jurisdiction over his motion. The Supreme Court, State of Wyoming found that Ruiz had filed his motion for sentence reduction beyond the one-year deadline stipulated by Wyoming Rule of Criminal Procedure (W.R.Cr.P.) 35(b). Therefore, the District Court correctly concluded it lacked jurisdiction over the motion. As a result, the Supreme Court, State of Wyoming also lacked jurisdiction to consider the appeal and dismissed it. The details of the case involve Ruiz's 2018 conviction for aggravated assault and battery, for which he was sentenced to seven to ten years in prison but placed on supervised probation for five years. After violating his probation in 2019, the original prison sentence was imposed. Ruiz attempted multiple times to have his sentence reduced or his conviction overturned, with all motions being dismissed by the District Court due to untimeliness or lack of jurisdiction. View "Ruiz v. The State of Wyoming" on Justia Law

The Supreme Court of Wyoming upheld a lower court's decision to grant a divorce, award the mother custody of two minor children, order the father to pay child support, and divide the marital property between the parties. The father had appealed the decision, challenging the court's division of property and its child support and custody decisions. The father and mother had been married since 2015 and had two children. The father was self-employed at a trucking company, and the mother stayed home with the children and homeschooled one of them. The court found that both parties could provide adequate care for the children, but that the mother had been their primary caretaker. The court also concluded that it was in the children's best interest for the mother to have custody. The court determined the father's net monthly income for child support purposes and ordered him to pay the mother monthly alimony for a period of time. The court also divided the marital property, awarding the mother more property because she had left established employment to be a homemaker and caretaker for the children. The Supreme Court determined that these decisions were a reasonable exercise of discretion by the lower court and affirmed the decision. View "Hyatt v. Hyatt" on Justia Law

In a case before the Supreme Court of the State of Wyoming, appellant Darrell Leonardo Alexander claimed that the district court erred in denying his motion to suppress evidence obtained by law enforcement after they entered his apartment without a warrant or his consent. The case revolved around the question of warrantless entry and consent.The court held that the warrantless entry into Alexander's apartment did not violate the Fourth Amendment. This was because the officers reasonably believed that Alexander's girlfriend, identified as E.B., had the apparent authority to consent to their entry. E.B. had called the police to report domestic violence, and when the officers arrived, she opened the door to the apartment and stepped inside, holding the door open for the officers. This action was seen as an invitation for the officers to enter the apartment.The court also found that E.B. had given implied consent for the officers to enter the apartment based on her nonverbal gestures and actions, such as opening the door and stepping inside when asked about the location of her boyfriend. Considering the totality of the circumstances, the court ruled that the officers' reliance on E.B.'s apparent authority to consent to their entry was reasonable. As such, the district court's decision to deny Alexander's motion to suppress the evidence was affirmed. View "Alexander v. The State of Wyoming" on Justia Law

Travis James Wright, found guilty of two counts of sexual exploitation of children, appealed the denial of his motion for sentence reduction by the District Court of Carbon County. He had been sentenced to two concurrent sentences of eight to ten years. Wright filed a pro se motion for sentence reduction, arguing prosecutorial misconduct, the proportionality of his sentence, and providing personal information and letters of support. The Supreme Court of Wyoming affirmed the lower court's decision, noting that the district court did not abuse its discretion in denying the motion. The court explained that it reviews rulings on motions for sentence reduction for abuse of discretion, and the sentencing judge is in the best position to decide about sentence modification. The court found that Wright's claims were not supported by cogent argument and were not appropriate under a Rule 35(b) motion, which cannot be used to attack the validity of a conviction or as a substitute for a properly filed appeal. The court also noted that productive behavior alone does not require the district court to grant a sentence reduction. View "Wright v. The State of Wyoming" on Justia Law