Justia Wyoming Supreme Court Opinion Summaries

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

The Supreme Court affirmed the decision of the Board of Equalization upholding the final determinations of the Department of Revenue (DOR) increasing the taxable value of Jonah Energy LLC's natural gas liquids (NGL) production for 2014 through 2016, holding that Jonah was not entitled to relief on its allegations of error.On appeal, Jonah argued that the Board misinterpreted the NGL purchase agreement between Jonah and the purchaser of its NGL, Enterprise Products Operating LLC, by refusing to account for deficiency fees Jonah paid to Enterprise in determining the NGL's taxable value. The Supreme Court affirmed, holding (1) the Board did not misinterpret the NGL purchase agreement at issue; and (2) the Board did not err by failing to take the facts and circumstances surrounding execution of the purchase agreement into account when interpreting it because there was no basis for losing outside the four corners of the purchase agreement to determine its meaning. View "Jonah Energy LLC v. Wyo. Dep't of Revenue" on Justia Law

The Supreme Court affirmed the judgment of the district court confirming the arbitration panel's finding that a non-compete clause Dr. Michel Skaf signed in his employment contract with Wyoming Cardiopulmonary Services (WCS) was unenforceable but that a previously-granted liquidation award was still valid, holding that there was no error.After WCS terminated Skaf for cause Skaf opened his own cardiology office. WCS sued Skaf for breaching the non-compete clause in the parties' employment contract. The arbitration found Skaf violated the noncompete clause and awarded WCS liquidated damages. The Supreme Court remanded the case. On remand, the arbitration panel again found in favor of WCS, that the non-compete clause was unenforceable, but that the liquidated damages award was still valid. The district court confirmed the award. The Supreme Court affirmed, holding (1) the panel did not commit manifest error by denying Skaf interest on his deferred compensation award; and (2) because Skaf did not previously appeal the panel's award, he was barred from doing so now. View "Skaf v. Wyo. Cardiopulmonary Services, P.C." on Justia Law

The Supreme Court affirmed the district court's award of $21,643.65 in attorney fees and costs to DAPCPA RPO, a full-service public accounting firm, after the court concluded that Defendant breached a purchase and sale agreement (PSA) and a covenant not to solicit, holding that there was no error.Defendant, a former employee of DAPCPA RPO, formed a new firm and provided services to former DAPCPA RPO clients. DAPCPA RPO filed suit, alleging several claims. The district court granted summary judgment for DAPCPA RPO in part, concluding that the parties' PSA and covenant not to solicit were valid and enforceable contracts and that Defendant breached them. Ultimately, the Court awarded DAPCPA RPO a total of $21,643.65 in attorney fees and costs. The Supreme Court affirmed, holding that the district court did not abuse its discretion in determining that DAPCPA RPO was entitled to its fees and costs. View "Hensel v. DAPCPA RPO LLC" on Justia Law

The Supreme Court affirmed Defendant's convictions of attempted murder, aggravated assault and battery, and other charges arising from a high-speed car purist and shootout with law enforcement officers, holding that the State did not commit prosecutorial misconduct.On appeal, Defendant argued that the State committed prosecutorial misconduct by presenting certain statements and information obtained from psychologists who conducted his competency and mental illness or deficiency evaluations. The Supreme Court disagreed and affirmed, holding that the record disclosed no gross prosecutorial impropriety that deprived Defendant of his right to a fair trial or attempt to persuade the trial court wrongly to convict him. View "Adams v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct illegal sentence, holding that the district court did not err by not awarding sentencing credit for time spent on probation and for time spent in substance abuse treatment as a condition of probation.Defendant pled guilty to felony driving under the influence. The district court suspended Defendant's suspended in favor of probation. The court later revoked Defendant's probation for violations of conditions of probation. Less than one year later, the court again revoked Defendant's probation. Defendant subsequently filed a letter that the district court construed as a motion to correct an illegal sentence, requesting credit for time spent in an inpatient treatment facility. The district court denied the request. The Supreme Court affirmed, holding that, under established precedent, the district court did not err in finding that Defendant was not entitled to credit for the time he participated in his treatment program. View "Hiltner v. State" on Justia Law

The Supreme Court reversed the judgment of the juvenile court changing the permanency plan in this case to adoption, holding that remand was required because the juvenile court failed to make the required reasonable efforts determination.In 2021, Child was taken into protective custody. The Department of Family Services (DFS) subsequently implemented a case plan for Mother and Child with the goal of family reunification. Eighteen months later, the court changed the permanency plan to adoption because Mother had made little to no progress on the plan. The order, however, contained no findings regarding DFS's reasonable efforts to reunite Mother and Child. The Supreme Court reversed, holding that because the juvenile court's written order was devoid of the required reasonable efforts determination remand was required for the juvenile court to make that determination. View "RN v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction on twenty-one counts related to his sexual abuse of his daughter AF, holding that Defendant was not entitled to relief on his allegations of error.At issue was whether the district court abused its discretion in admitting a sexually explicit photograph of AF's mother, Mrs. Freer, and a pornographic father-daughter incest video under Wyo. R. Evid. 404(b). The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting the sexually explicit photograph of Mrs. Freer and the pornographic incest video; (2) Defendant failed to demonstrate that alleged prosecutorial misconduct denied him his right to a fair trial. View "Freer v. Wyoming" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of Laramie Investment Company and its owner and president, Brad Jackson (collectively, Defendants), and dismissing Plaintiffs' action for breach of contract, negligence, and "reasonable expectations," holding that there was no error in the proceedings below. Plaintiffs, who contracted with Defendants to obtain an insurance policy for their ranch and surrounding outbuildings, brought this suit two years after a tornado destroyed their home and an outbuilding. Plaintiffs discovered that the insurance policy did not cover the outbuilding or its contents but did not bring suit until the two-year anniversary of the tornado. The district court granted summary judgment for Defendants on statute of limitations grounds. The Supreme Court affirmed, holding (1) Jackson was a "professional" under Wyo. Stat. Ann. 1-3-107; (2) the statute of limitations began running when the insurance policy was issued; (3) the district court correctly granted Defendants' motion for summary judgment; and (4) the "continuous care doctrine" did not apply to the facts of this case. View "Falkenburg v. Laramie Investment Co." on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se motion to correct an illegal sentence, holding that the district court did not abuse its discretion in denying the motion.In his motion to correct an illegal sentence, Appellant argued that his two sentences for delivery of a controlled substance should be concurrent because the charges appeared in the same charging document, arose from the same arrest, and were tried under the same district court docket number. The district court denied the motion. The Supreme Court affirmed, holding (1) the two charges for delivery of methamphetamine were separate offenses arising from different transactions; and (2) the trial court did not violate double jeopardy protections by entering consecutive sentences for the two offenses. View "Veatch v. State" on Justia Law