Justia Wyoming Supreme Court Opinion Summaries

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

The Supreme Court affirmed Defendant's conviction and sentence for possession and delivery of methamphetamine, holding that the district court did not err in denying Defendant's motion for a sentence reduction pursuant to Wyo. R. Crim. P. 35(b).Defendant was charged with five felony offenses related to possession and delivery of a controlled substance and, pursuant to a plea agreement, pled guilty to one count of possession and one count of delivery of methamphetamine. The district court sentenced Defendant to five to seven years on the possession charge and a consecutive sentence of ten to fifteen years on the delivery charge. Defendant later filed her motion for sentence reduction, which the district court denied. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it did not elaborate on its reasons for denying Defendant's motion for sentence reduction and that there was no other error in the proceedings. View "Hurtado v. State" on Justia Law

The Supreme Court reversed the order of the district court granting Mother's motion for default and making final a temporary child support order from 2018, holding that the district court erred.In this appeal, Father challenged a district court order granting Mother's motion for default and making final a 2018 temporary child support order, arguing, among other things, that the district court violated his right to due process by granting Motion's motion for default before the closing of his twenty-day response window under Wyo. R. Civ. P. 6(c)(2). The Supreme Court reversed, holding (1) Father timely filed his notice of appeal, and therefore, this Court had jurisdiction; (2) the district court violated Father's right to due process by granting Mother's motion before Father's opportunity to respond expired; and (3) the district court abused its discretion by making the 2018 temporary child support order the final order without obtaining sufficient financial information under Wyo. Stat. Ann. 20-2-308. View "Tucker v. Tucker" on Justia Law

The Supreme Court dismissed for lack of jurisdiction this appeal from the order of the district court dismissing Appellant's appeal of the Natrona County Board of Commissioners' decision denying Appellant's application to transfer a liquor license to him, holding that the district court did not have subject matter jurisdiction.In a separate lawsuit, the district court ordered the CC Cowboys, Inc.'s (CCCI) liquor license be transferred to Appellant. Appellant applied to the Board for the transfer of CCCI's liquor license, but the Board denied the transfer on the grounds that the "transfer will adversely affect the welfare of the people residing in the vicinity of the proposed license address." Appellant appealed to the district court, which found that it lacked jurisdiction to review the proceedings. The Supreme Court affirmed, holding that the district court correctly determined that it was without jurisdiction. View "Elliott v. Natrona County Bd. of Commissioners" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant, following a jury trial, of two counts of second-degree sexual abuse of a minor, holding that the prosecutor did not commit prosecutorial misconduct in the underlying proceedings.On appeal, Defendant argued that the prosecutor committed misconduct in the way he referred to and used the testimony of a forensic interviewer in his opening statement and closing argument. The Supreme Court disagreed and affirmed, holding (1) Defendant failed to establish that the prosecutor's statement violated a clear and unequivocal rule of law; and (2) there was no plain error in the State's closing argument. View "State v. Ward" on Justia Law

The Supreme Court answered a certified question by concluding that Wyo. Stat. Ann. 7-11-303 expressly grants circuit courts jurisdiction to address the competency of a person charged with a felony and suspend preliminary hearings before the person is bound over to the district court.Defendant was charged with two felonies. Before the preliminary hearing, defense counsel moved for a competency evaluation under section 7-11-303. The circuit court granted the motion and, after an evaluation, found Defendant fit to proceed. Thereafter, a preliminary hearing was held, and the matter was bound over to the district court. While the competency evaluation was pending the prosecutor filed an action seeking a writ of mandamus to compel the circuit court to hold a preliminary hearing. The circuit court certified the matter to the Supreme Court. The Supreme Court answered that the plain language of section 7-11-303(a) confers jurisdiction to circuit courts to address the competency of a person charged with a felony before they are bound over to the district court. View "Skoric v. Park County Circuit Court" on Justia Law

The Supreme Court affirmed the judgments of the district courts denying Appellants' separate motions to suppress, holding that the Wyoming Constitution does not require that an exterior canine sniff of a vehicle be supported by probable cause.Appellants in these cases were both subjected to an extended investigative detention, and both Appellants were arrested after a canine sniff of their vehicles. On appeal, Appellants argued that the canine sniffs had to be supported by probable cause under Wyo. Const. art. I, 4. The Supreme Court disagreed, holding (1) the Wyoming Constitution does not require probable cause for an exterior canine sniff of a vehicle; and (2) Appellants were not entitled to relief on their remaining allegations of error. View "Tarzia v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the district court's order finding Mother in contempt and modifying the underlying divorce decree, holding that the district court's finding of contempt must be reversed.The parties' divorce decree granted joint custody of the parties' two children. Mother later filed a petition to modify custody, seeking sole legal and primary residential custody of the children. Father responded with his own petition to modify custody. Father also sought to hold Mother in contempt. The district court (1) found Mother in contempt for unreasonably withholding visitation, unreasonably denying Father's requests to travel with the children, and failing to return Father's medical records; and (2) found that modification of the decree was justified. The Supreme Court reversed in part, holding (1) the district court abused its discretion when it determined that clear and convincing evidence supporting finding Mother in contempt of court because the decree was ambiguous; (2) the district court did not abuse its discretion when it modified the decree to clarify its travel and visitation provisions; and (3) Mother was not entitled to relief on her remaining claims of error. View "Evans v. Sharpe" on Justia Law

The Supreme Court affirmed the judgment of the district court ruling in favor of Jacqueline Moncur and Rosemary Kinniburgh, co-trustees of the J. Kent Kinniburgh Revocable Trust, in this lawsuit brought by Janel Kinniburgh, one of the beneficiaries of the Trust, holding that the district court did not err.Janel, one of the trustees of the Trust, brought this action against her sisters, alleging that they breached certain fiduciary duties. The district court ruled in favor of the Trustees on most claims, concluding that the Trustees breached their duties of loyalty and impartiality but finding that Janel failed prove damages resulting from that breach. The Supreme Court affirmed, holding that the district court (1) erred when it found that the Trustees did not breach their duty to inform and report, but Janel failed to show that the Trust sustained damages; (2) did not err in concluding that the Trustees did not breach their duties of impartiality or prudent administration; and (3) did not err in deciding not to award attorney fees, monetary damages, or remove the Trustees. View "Kinniburgh v. Moncur" on Justia Law