Justia Wyoming Supreme Court Opinion Summaries

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

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