Justia Wyoming Supreme Court Opinion Summaries

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revocation proceeding.Defendant admitted to the State's allegations of probation violations, and his probation was revoked and sentence reinstated.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

The Supreme Court affirmed Defendant's conviction for interference with a peace officer, holding that the district court did not violate Defendant's due process rights by conducting a hearing under Asch v. State, 62 P.3d 945 (Wyo. 2003), in Defendant's absence after he refused to attend the hearing.Defendant, who was serving three consecutive life sentences at the Wyoming State Penitentiary, was charged with interference with a peace officer. Before the scheduled trial date, the State moved to require Defendant to be restrained during trial. The district court conducted an Asch hearing without Defendant and decided to impose restraints at trial. Defendant was convicted of one count of felony interference with a peace officer. The Supreme Court affirmed, holding that Defendant waived any right he had to be present at the Asch hearing by knowingly and voluntarily failing to appear at the hearing due to circumstances within his control. View "Castellanos v. State" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of Shelby Hughes and her law firm, Barney & Graham, LLC, (collectively, Defendants) in the underlying legal malpractice lawsuit, holding that the district court did not err.Michael and Charlene Schlegel were in the process of divorcing when Michael died intestate. Because Charlene inherited portions of Michael's estate that she would not have had the divorce been finalized before Michael died Taran Schlegal, Michael's son, sued Defendants for legal malpractice. The district court granted summary judgment for Defendants, finding that no duty was owed to Taran where there was no evidence that Taran was an intended beneficiary of Defendants' services. View "Schlegel v. Barney & Graham, LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Medical Commission to uphold the determination of the Department of Workforce Services, Workers' Compensation Division that Jon Bressler was not entitled to compensation for three physical therapy sessions in connection with his work-related injury to his right arm, holding that there was no error.The Supreme Court affirmed the order upholding the three final determinations of the Division denying Bressler physical therapy benefits, holding that the Commission's conclusion that Bressler's continued physical therapy was not reasonable and necessary medical care for his work-related injury was supported by substantial evidence. View "Bressler v. State, ex rel. Dep't of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court affirmed Defendant's conviction of failing to notify law enforcement of a change in his residential address, holding that the State presented sufficient evidence at trial to support the conviction.After a jury trial, Defendant was found guilty of two violations of the Sex Offender Registration Act for failing to notify law enforcement of a change in his residential address. Defendant appealed, arguing that there was insufficient evidence presented at trial to support his conviction. The Supreme Court affirmed, holding that the evidence was clearly sufficient to show that Defendant was required and failed to register two residential addresses. View "Martens v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion for sentence reduction, holding that the district court erred in ruling that the motion was untimely but that the error was harmless.After a jury trial, Defendant was found guilty of several crimes, including aggravated burglary. The court sentenced Defendant to a total of twelve to twenty years followed by seven years of probation. The Supreme Court affirmed, holding (1) the district court erred in ruling that Defendant's motion for sentence reduction was untimely, but the error was harmless; and (2) the district court did not abuse its discretion in denying Defendant's motion for sentence reduction. View "Buckingham v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of four counts of sexual abuse of a minor in the first degree soliciting to engage in illicit sexual relations, attempt to commit sexual abuse o a minor in the second degree, and battery, holding that there was no abuse of discretion or cumulative error.Specifically, the Supreme Court held (1) the district court did not abuse its discretion by admitting hearsay evidence in violation of Wyo. R. Evid. 802; (2) the district court did not abuse its discretion by admitting evidence in violation of Wyo. R. Evid. 403; and (3) because there was no error, there was no basis for Defendant's claim that evidentiary errors cumulatively deprived him of a fair trial. View "Munda v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's petition filed under the Post-Conviction Determination of Factual Innocence Act alleging that he was factually innocent of three convictions because the victim recanted her trial testimony, holding that the district court did not clearly err.After he was convicted of five counts of sexual assault and sexual abuse of a minor involving two victims Appellant petitioned the district court asserting that he was factually innocent based on the victim's recantation. After a hearing, the district court found that Appellant did not offer clear and convincing evidence of his innocence and denied the petition on the merits. The Supreme Court affirmed, holding that there was no basis for this Court to disturb the district court's ruling. View "Shawn v. State" on Justia Law

The Supreme Court affirmed Defendant's sentence and the order of the district court denying Defendant's motion for a sentence reduction and correction, holding that there was no error.Defendant was convicted of six counts of aggravated child abuse and sentenced to concurrent prison terms of four to eight years on each count. In his motion for a sentence reduction and correction Defendant argued that his sentence was illegal on several grounds. The district court denied the motion. On appeal, Defendant argued, among other things, that the court failed adequately to consider probation and that his sentence was further illegal on several grounds. The Supreme Court affirmed, holding (1) the record did not support Defendant's claim that the district court failed to consider a sentence of probation; (2) the presentence investigation report's lack of a recommendation on probation did not render Defendant's sentence illegal; and (3) Defendant's sentence was not cruel or unusual. View "Martinson v. State" on Justia Law