Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the district court in this dispute between the children and grandchildren of Martin and Gay Aimone regarding their inheritances and ownership interests in the family ranch, holding that the court erred in part.In one appeal, the Aimones' surviving children (Chris and Colleen) challenged the district court's reformation of Gay's trust to reflect her intention that her surviving children and grandchildren be beneficiaries under the trust. In the second appeal, four of the Aimones' grandchildren (the Aimones brothers) argued that the district court improperly rejected their claims that Chris and Colleen violated their fiduciary obligations as the manager of one of the Aimone entities and as trustee of the trust. The Supreme Court (1) affirmed the district court's ruling in the first appeal concerning the intention of the trust; but (2) reversed the ruling in the second appeal, holding that Chris breached her fiduciary duties to the Aimone entity and should be removed as manager and that Colleen breached her fiduciary duties to Gay's trust, but damages were not proven to a reasonable degree of certainty. View "Aimone v. Aimone" on Justia Law

The Supreme Court affirmed the judgment of the juvenile court changing the permanency plan for a minor child (Child) from reunification to adoption, holding that there was no error.In 2021, the State filed a petition against Mother alleging neglect of Child. The juvenile court removed Child from the home follow a hearing and placed Child into non-relative foster care. In 2022, the Department of Family Services (DFS) recommended that the juvenile court change the permanency plan from reunification to adoption. The juvenile court conducted an evidentiary hearing and then issued an order changing the permanency plan from reunification to adoption. The Supreme Court affirmed, holding (1) the juvenile court did not err in excluding Child's maternal grandmother as a placement option; (2) the juvenile court did not err in changing the permanency plan from reunification to adoption and allowing DFS to cease further reunification efforts; and (3) Father was not materially prejudiced by his absence from a shelter care hearing. View "AG v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained after law enforcement forced open a lacked box during an inventory search of Defendant's vehicle, holding that the district court did not err.During an inventory search of Defendant's vehicle, the police forced open a locked box and discovered suspected illegal drugs. The State charged Defendant with felony possession of methamphetamine and misdemeanor possession of heroin. Defendant moved to suppress the evidence obtained from the box, arguing that opening the box exceeded the scope of a permissible inventory search in violation of the Wyoming Highway Patrol's (WHP) inventory policy, thus violating his Fourth Amendment rights. The district court denied the motion, after which Defendant entered a conditional plea of guilty to felony possession of methamphetamine. The Supreme Court affirmed, holding that Defendant's argument that the inventory search violated WHP policy was unavailing. View "Beckwith v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion for sentence reduction, holding that Defendant was not entitled to relief on his claim that the district court abused its discretion by relying upon the State's misrepresentation of Defendant's criminal history when denying his motion.Defendant pled guilty pursuant to a plea agreement to felony domestic battery and was sentenced to three to six years in prison. Defendant later filed a pro se motion for sentence reduction. The district court denied the motion. The Supreme Court affirmed, holding that where Defendant failed to show that the district court actually relied upon the State's misrepresentation of his criminal history when denying his motion for sentence reduction, the district court did not abuse its discretion by denying the motion. View "Bulisco v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of third-degree sexual abuse of a minor, holding that there was sufficient evidence to support the conviction.Defendant was convicted of sexually assaulting his niece, DT. On appeal, Defendant argued that DT's testimony during trial lacked credibility and could not support his conviction and that, alternatively, the State was only able to establish the first element of the offense through leading questions. The Supreme Court rejected Defendant's arguments and affirmed, holding that the evidence was sufficient to support the jury's verdict. View "Deephouse v. State" on Justia Law

The Supreme Court reversed the judgment of the district court granting Defendant's petition for relief from the requirement that Defendant register as a sex offender in Wyoming pursuant to the Wyoming Sex Offender Registration Act, holding that the district court's rulings concerning Wyoming Division of Criminal Investigation's (DCI) authority under the Act were erroneous.In 1999, Defendant pleaded guilty to misdemeanor sexual battery in Georgia. In 2019, a federal agency informed DCI that that it had intercepted a firearm suppressor addressed to Defendant, who was living in Casper, Wyoming. After discovering his Georgia conviction, DCI directed Defendant to register as a sex offender in the state. Defendant filed a petition seeking relief from the requirement. The district court granted DCI summary judgment. The Supreme Court reversed, holding (1) because the Act's requirement to register as a sex offender is premised on a conviction, DCI may not rely on dismissed charges to determine an individual's registration requirements; and (2) DCI may not require someone to register before it knows that he was convicted of a registrable offense. View "Minter v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of immodest, immoral, and indecent liberties with a minor, third-degree sexual assault, and first-degree sexual abuse of a minor, holding that Defendant was not entitled to relief on his four allegations of error.Specifically, the Supreme Court held (1) the evidence was sufficient to support Defendant's conviction of third-degree sexual assault; (2) the trial court erred in admitting certain evidence, but Defendant was not prejudiced by the error; (3) the prosecutor made a statement during the State's closing argument regarding the victim's veracity, but Defendant was not prejudiced by the error; and (4) there was no reasonable possibility that cumulative effect of the errors at trial deprived Defendant of a fair trial. View "King v. State" on Justia Law

The First Circuit affirmed in part and reversed in part Petitioners' petition for a writ of review seeking interlocutory review of the orders of the district court denying Petitioners' motion to dismiss and motion to set aside default, holding that the district court abused its discretion in denying the motion to set aside the default judgment.At issue was subject matter jurisdiction and personal jurisdiction based on service by publication. Petitioners argued that the failure to serve Defendants with a summons stripped the district court of both subject matter jurisdiction and personal jurisdiction. The First Circuit held (1) absent a statute or rule to the contrary, no summons is required when service is accomplished by publication; (2) the district court correctly determined that a summons is not required as to those defendants who are properly subject to service by publication; but (3) the court erred in finding the service by publication conferred personal jurisdiction over the defendants with a known address. View "Hopeful v. Etchepare, LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court after a trial quieting title of certain property in favor of Appellees, the owners of the Warbonnet Ranch, after finding that Appellant, the owner of the Burnett Ranch, failed to meet its prima facie case establishing the elements of adverse possession, holding that there was no error.The Burnett Ranch was enclosed by a perimeter fence, within which were three non-contiguous parcels of property (subject property) that were part of the Warbonnet Ranch and deeded to Appellees. Appellant brought this action asserting that it owned the subject property by adverse possession through its use of the property for grazing cattle and by maintaining the permitter fence. The district court entered summary judgment for Appellees, but the Supreme Court reversed on the grounds that genuine issues of material fact existed. On remand, after a trial, the trial court entered judgment for Appellees. The Supreme Court affirmed, holding that the district court's findings were not clearly erroneous. View "Little Medicine Creek Ranch, Inc. v. d'Elia" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Board of County Commissioners of Albany County approving ConnectGen Albany County LLC's application for a Wind Energy Conversion System (WECS) permit to construct a wind farm on Albany County land, holding that Appellants were not entitled to relief.Specifically, the Supreme Court held (1) contrary to Appellants' argument on appeal, ConnectGen was not required to obtain a conditional use permit in addition to the WECS special use permit; (2) the Board's approval of the WECS special use permit was not arbitrary or capricious; and (3) Appellants failed to establish that the Board's approval of the WECS special use permit was a taking of private property in violation of Wyo. Const. art. 1, 32. View "Aanonsen v. Bd. of County Commissioners of Albany County" on Justia Law