Justia Wyoming Supreme Court Opinion Summaries

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

The Supreme Court affirmed Defendant's conviction of four counts of aggravated assault and battery, holding that the State presented sufficient evidence to support Defendant's aggravated assault and battery convictions.After a jury trial, Defendant was found guilty of four counts of aggravated assault and battery, in violation of Wyo. Stat. Ann. 6-2-502(a)(iii). The district court sentenced Defendant to an aggregate term of forty-two to 108 months' imprisonment. The Supreme Court affirmed, holding that the trial evidence was sufficient for the jury to have found a reasonable doubt all elements of Defendant's conviction. View "Thunder v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion seeking presentence time served credit against his felony drug sentences, holding that Defendant was not entitled to presentence confinement credit against the sentences in the felony drug possession docket.In 2014, Defendant was sentenced on two felony counts of DUI. In 2020, Defendant was arrested and charged with five felonies, including probation violations in his two previous cases. Defendant admitted to the probation violations and pled guilty to two felony drug possession counts. After he was sentenced Defendant filed a pro se motion for time served in presentence incarceration, arguing that he should have received credit for the time served after his arrest and before sentencing. The district court denied the motion. The Supreme Court affirmed, holding that Defendant, who received presentence confinement credit against the sentences in his probation violation cases, was not also entitled to presentnence confinement credit against the sentences in the felony drug possession docket. View "Greene v. State" on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment against Steven Johnson and his legal entities (collectively, Appellants) on Johnson's legal malpractice claims against Danielle M. Mathey and Mathey Law Office, P.C. (collectively, Appellees), holding that Appellees were entitled to judgment as a matter of law.Appellants sued Appellees alleging legal malpractice regarding Mathey's representation of Johnson on various matters. Because Appellants did not designate an expert witness or present any competent evidence establishing the legal elements of their legal malpractice claims the district court granted summary judgment for Appeellees, finding that Appellants failed to establish through expert testimony or other competent evidence a genuine issue of material fact on the elements of their claims. The Supreme Court affirmed, holding that, under the facts of this case, the district court properly granted summary judgment in favor of Appellees. View "Johnson v. Mathey" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellants' joint motion to suppress more than 300 pounds of marijuana law enforcement discovered during a traffic stop on Interstate 80 in Wyoming, holding that the district court did not err when it denied Appellants' motion to suppress evidence.Appellants - Cristian Ramirez and Hector Zapien-Galvan - were pulled over by state troopers for an expired registration. Appellants refused to consent to a search of the car, after which a certified canine alerted to packages containing 320.6 pounds of marijuana. Appellants moved to suppress the evidence, arguing that the officer's conduct in pursuing their vehicle without reasonable suspicion negated the subsequent probable cause for the search. The district court denied the motion. The Supreme Court affirmed, holding that the district court properly denied Appellants' motion to suppress because the underlying traffic stop was both objectively justified and reasonable at its inception and did not violate Wyo. Const. art. I, 4 or the Fourth Amendment. View "Zapien-Galvan v. State" on Justia Law

The Supreme Court affirmed the order of the district court modifying Father's child support, holding that Mother was not entitled to relief on her allegations of error.On appeal, Mother argued that the district court abused its discretion when it calculated Father's net monthly income without first obtaining sufficient financial information and by calculating her net monthly income contrary to the evidence on the record. The Supreme Court affirmed, holding that the district court (1) obtained sufficient financial information to calculate Father's net monthly income; and (2) did not abuse its discretion in calculating Mother's net monthly income. View "Corbitt v. Davidson" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to withdraw his pleas of no contest to voluntary manslaughter, attempted voluntary manslaughter, two counts of aggravated robbery, and four counts of interference with a peace officer, holding that the district court did not abuse its discretion when it denied Defendant's motion to withdraw his no contest pleas.Defendant pleaded no contest to the charges against him pursuant to a plea agreement with the State. Before he was sentenced, Defendant moved to withdraw his pleas, arguing that his right to a speedy trial was violated and that defense counsel did not provide effective assistance of counsel. The district court denied the motion and sentenced Defendant according to the plea agreement. That Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant's motion to withdraw his pleas. View "McHenry v. State" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of Defendant and dismissing Plaintiffs' complaint seeking to recover damages for the emotional distress they allegedly suffered when their dogs died after becoming entangled in Defendant's snares, holding that there was no error.In his motion for summary judgment, Defendant asserted that Plaintiffs' emotional distress were not compensable because dogs are considered property. The district court granted the motion. The Supreme Court affirmed, holding (1) under Wyoming law, dogs are property; (2) while Plaintiffs might be entitled to emotional damages for their own injuries, the impact rule did not extend their recovery to emotional damages caused by the dogs' death; and (3) Plaintiffs' argument that recovery for emotional distress damages should be allowed when animate property is negligently harmed is best made to the legislature. View "Cardenas v. Swanson" on Justia Law

The Supreme Court affirmed Defendant's conviction, entered upon his conditional plea of guilty, of felony possession of methamphetamine, holding that the district court did not err in denying Defendant's motion to suppress evidence obtained from his vehicle after law enforcement stopped him for failing properly to signal a left turn.On appeal, Defendant challenged the district court's interpretation of the applicable statute, Wyo. Stat. Ann. 31-5-217, arguing that he complied with the statute and that the officer lacked reasonable suspicion to stop him. The Supreme Court affirmed, holding that Defendant's argument that this Court should interpret the statute to require no more than a turn be made safely ignored the rules of statutory interpretation. View "Anderson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court awarding Mother primary custody of the couple's two children and dividing the marital property, holding that the district court did not err or abuse its discretion.Father filed for divorce, and Mother counterclaimed for divorce. After a trial, the district court granted the parties a decree, awarded Mother primary custody of the parties' two children, ordered Father to pay Mother monthly child support, and divided the marital property. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by admitting the opinion testimony and report of one of Mother's witnesses because Mother's failure to designate that witness as an expert witness was harmless; and (2) did not abuse its discretion by granting Mother primary custody or in its division of the marital property. View "Dutka v. Dutka" on Justia Law