Justia Wyoming Supreme Court Opinion Summaries

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

The Supreme Court reversed the summary judgment order of the district court requiring Memorial Hospital of Converse County (MHCC) to produce certain records requested under the Wyoming Public Records Act (WPRA) but also imposing a protective order on those documents, holding that the district court erred in finding that a certain document was not subject to disclosure under the WPRA.On appeal, Plaintiff challenged the denial of her motion for summary judgment related to the production of documents involving a settlement between MHCC and a patient (MB settlement), arguing that the MB settlement was subject to production under the WPRA. The Supreme Court reversed, holding (1) the district court erred should have ordered MHCC to produce the MB settlement; and (2) the district court's entry of a protective order was contrary to the WPRA and without evidentiary support. View "Gates v. "Memorial Hospital of Converse County - Advanced Medicine. Hometown Care", ex rel. Board of Trustees of the Memorial Hospital of Converse County" on Justia Law

The Supreme Court affirmed Defendant's conviction of ten sex crimes against two sisters, A.S. and T.S., holding that Defendant was not entitled to relief on his allegations of error.The State charged Defendant with a total of twenty-two crimes against A.S. and T.S. The jury convicted him of ten of the charges, and the district court sentenced him to seventy-one to eighty-five years in prison. The Supreme Court affirmed, holding (1) Defendant failed to establish that the State violated his right to due process of law under Brady or Giglio; (2) Defendant did not show that his counsel performed deficiently or that his defense was prejudiced by counsel's actions at trial; and (3) the State presented sufficient evidence to support Defendant's convictions for the first-degree sexual assault against T.S. View "Mills v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of aggravated cruelty to animals, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant abandoned his argument that the district court erred when it allowed his wife to invoke spousal privilege in the presence of the jury; (2) the district court did not abuse its discretion when it admitted testimony and evidence from a witness who was not disclosed pretrial; (3) Defendant was not prejudiced by prosecutorial misconduct; and (4) Defendant failed to satisfy the plain error test as to his argument that the district court violated his right against self-incrimination under the Federal and Wyoming Constitutions when it ordered him to participate in the preparation of a presentence investigation as a condition of his bond. View "Berry v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion for sentence reduction and motion to correct an illegal sentence, holding that the district court did not abuse its discretion in denying either motion.Defendant entered an Alford plea to two counts of sexual abuse of a minor child in the third degree and was sentenced to two concurrent terms of three to five years' incarceration. Defendant later filed his second motion for sentence reduction and a motion to correct an illegal sentence. The district court denied both motions. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant's motion for sentence reduction and his motion to correct an illegal sentence. View "Dillard v. State" on Justia Law