Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the district court holding Nicole and Andy Ward in contempt for failing to comply with a visitation order and then issuing an order modifying Brett and Isabel Beldens' visitation to better accommodate the parties' needs and obligations, holding that there was no error.In 2019, the Beldens, the grandparents of the children of their deceased son, were granted visitation after their relationship with Nicole soured. In 2022, Andy the children's stepfather, adopted the children. Thereafter, the Wards informed the Beldens that they would no longer comply with the order of grandparent visitation. The Beldens filed a motion to enforce the visitation order, and the Wards filed a petition to modify the visitation order. The district court (1) held the Wards in contempt for their failure to comply with the original visitation order; and (2) modified the Beldens' visitation after finding that good cause existed to amend the order. View "Ward v. Belden" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of C.H. Yarber Construction in this action brought by West American Insurance Company seeking subrogation and asserting claims of negligence and breach of contract, holding that West could not pursue its claims against C.H. Yarber in subrogation.C.H. Yarber was the tenant leasing Profile Properties' commercial property in Cheyenne when the property sustained damage from a fire. West, the insurer of the property, covered Profile's fire damages and proceeded against C.H. Yarber in subrogation. The district court concluded that West could not pursue its claims in subrogation because D.H. Yarber was a co-insured under Profile's insurance policy. The Supreme Court affirmed, holding that because the relevant lease evidenced that Profile did not intend to look to C.H. Yarber to cover the insured loss, West could not pursue its claims against C.H. Yarber in subrogation. View "West American Insurance Co. v. Black Dog Consulting Inc." on Justia Law

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