Justia Wyoming Supreme Court Opinion Summaries

Between October 31, 2022, and February 9, 2023, several burglaries occurred in Sheridan County, Wyoming. Surveillance videos captured a suspect wearing a beanie, facemask, and hooded sweatshirt or silver puffer jacket, often holding a flashlight and leaving distinctive footprints. By mid-February 2023, the Sheridan County Sheriff’s office identified William Corey Holliday as a suspect. A search of his residence and vehicle revealed clothing and shoes matching those seen in the videos, and stolen items from the burglaries. Holliday was charged with 20 counts of burglary, later amended to 23 counts.The District Court of Sheridan County held a six-day trial beginning November 3, 2023. Approximately 50 witnesses testified. During the trial, the prosecutor referred to the person in the surveillance videos as “the Defendant” while questioning two witnesses. Defense counsel objected to one instance, and the court sustained the objection. The prosecutor later acknowledged the inadvertent use of the term and the court issued a curative instruction to the jury, emphasizing that the identity of the person in the videos was for the jury to decide. The jury found Holliday guilty of 15 counts and not guilty of 3 counts. He was sentenced to 5 to 10 years in prison for each count, to be served concurrently.The Supreme Court of Wyoming reviewed the case. Holliday argued that the prosecutor committed misconduct by vouching for the element of identity. The court held that while the prosecutor’s references were improper, they did not amount to prosecutorial misconduct. The court found that the overwhelming evidence against Holliday and the district court’s curative instructions mitigated any potential prejudice. The court affirmed Holliday’s convictions. View "Holliday v. The State of Wyoming" on Justia Law

A couple, married in 2001, had three children and lived in Cheyenne, Wyoming. The husband worked in his family's steel business and later managed his own company, while the wife initially stayed home with the children and later took over her father's consulting firm. They separated in October 2020, with the husband moving to Colorado and the wife staying in the marital home with the children. The wife filed for divorce in September 2021, and the husband counterclaimed. By May 2022, their eldest child turned 18, and by July 2022, their middle child began living with the husband.The District Court of Laramie County held a two-day bench trial in January 2024. The court granted the divorce, awarded shared legal custody of the children, and split physical custody. The husband was ordered to pay $67.79 in monthly child support. The court divided the marital property, valuing the husband's business interests and awarding the marital home to the wife, along with all associated debts. The husband was ordered to pay the wife $400,000 to achieve an equitable distribution of assets. The wife appealed, challenging the denial of retroactive child support and the valuation of the marital home.The Wyoming Supreme Court reviewed the case. It found no abuse of discretion by the district court in denying retroactive child support, noting that both parties had jointly provided for the children's needs during the separation. The court also upheld the district court's valuation of the marital home, affirming that the mortgage was accounted for in the property division. The Supreme Court affirmed the district court's decisions. View "Lewis v. Lewis" on Justia Law

Tirso Munguia pleaded guilty to involuntary manslaughter under a plea agreement where the State agreed to recommend an eight to twelve-year sentence. However, after Munguia violated his bond conditions by contacting the victim's family, the State argued for the maximum sentence, and the court imposed a fifteen to twenty-year sentence. Munguia appealed, claiming the court abused its discretion in revoking his bond and that the State violated the plea agreement.The District Court of Laramie County initially accepted Munguia's guilty plea and the plea agreement, which included a "cold plea" provision allowing the State to withdraw its sentencing recommendation if Munguia violated any bond conditions. After Munguia's bond was modified to prohibit contact with the victim's family, the State filed a petition to revoke his bond, alleging such contact. The district court found clear and convincing evidence of the bond violation and revoked his bond, placing him on house arrest. At sentencing, the State argued for the maximum sentence due to the bond violation, and the court sentenced Munguia to fifteen to twenty years.The Wyoming Supreme Court reviewed the case and affirmed the lower court's decisions. The court held that the district court did not abuse its discretion in finding that Munguia violated his bond conditions, as the evidence supported the conclusion that he knowingly contacted the victim's family. The court also held that the State did not breach the plea agreement by arguing for a harsher sentence after the bond violation, as the "cold plea" provision explicitly allowed for this. The court found no error in the district court's decisions and affirmed the sentence. View "Munguia v. The State of Wyoming" on Justia Law

Brandon Serini was arrested by Officer Nathaniel Lucero of the Cheyenne Police Department after it was confirmed that Serini had an outstanding warrant for his arrest. At the time of his arrest, Serini was in possession of a backpack, which was seized by the officers. The backpack was later searched at the police department, where methamphetamine was found. Serini was charged with felony possession of methamphetamine and filed a motion to suppress the evidence obtained from the search of his backpack, arguing that the search was unreasonable and violated the Fourth Amendment.The District Court of Laramie County denied Serini's motion to suppress, finding that the officers acted in good faith and in accordance with the Cheyenne Police Department’s standardized policy when they seized and conducted an inventory search of the backpack. The court held that the seizure and search were permissible under the community caretaker function and the inventory search exception to the warrant requirement.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decision. The court held that the seizure and search of Serini’s backpack were reasonable and did not violate the Fourth Amendment. The court found that the officers did not act in bad faith or with a pretextual purpose to investigate further. Instead, they followed standardized procedures to safeguard Serini’s property, especially considering his homeless status. The court concluded that the inventory search was conducted in accordance with the police department’s policy and was a valid exception to the warrant requirement. The decision of the district court to deny the motion to suppress was affirmed. View "Serini v. The State of Wyoming" on Justia Law

Katrina Danforth appealed the termination of her parental rights to her child, SLD. The case began when Ryan Hansen, the child's father, filed a petition to terminate Danforth's parental rights, citing her felony conviction for a murder-for-hire plot against him. Danforth counterclaimed, seeking to terminate Hansen's parental rights, and requested the appointment of a guardian ad litem (GAL) for SLD. The Department of Family Services conducted a social study, which Danforth argued was inadequate because it did not include her input.The District Court of Sheridan County held a bench trial and terminated Danforth's parental rights. The court found that Hansen adequately represented SLD's interests and that a GAL was unnecessary. Danforth's counterclaim was dismissed without a separate evidentiary hearing, as she did not present evidence to support it during the trial. Danforth appealed, arguing that the social study was prejudicial, the denial of a GAL was erroneous, her counterclaim should not have been dismissed without a hearing, and that the termination of her parental rights unjustly extended her punishment for her past crime.The Wyoming Supreme Court reviewed the case and affirmed the lower court's decisions. The court found that the social study complied with statutory requirements and did not prejudice Danforth, as she had the opportunity to testify about her situation. The court also held that the district court did not err in finding a GAL unnecessary, as Hansen adequately represented SLD's interests. The dismissal of Danforth's counterclaim without a separate hearing was upheld because she failed to prosecute it during the trial. Finally, the court concluded that the termination of Danforth's parental rights was based on statutory grounds and SLD's best interests, not as an extension of her criminal punishment. View "In re Termination of Parental Rights To SLD v. Hansen" on Justia Law

A personal representative of a deceased resident's estate filed a complaint against a hospital district and its associated rehabilitation center, alleging negligence and vicarious liability for injuries suffered by the resident due to physical abuse by a temporary certified nursing assistant (CNA). The hospital district denied liability, claiming the CNA was an independent contractor. After a six-day trial, the jury found the CNA was an agent of the hospital district, and her negligence was a proximate cause of the resident's damages. The jury apportioned fault between the CNA and the hospital district, awarding $660,000 in damages to the estate.The district court reduced the damages by the percentage of fault attributed to the CNA, leading to an appeal by the personal representative, who argued the reduction was contrary to Wyoming law and inconsistent with the jury's verdict. The hospital district cross-appealed, asserting the district court should not have allowed the jury to consider whether the CNA was an agent and should have granted its motion for judgment as a matter of law.The Wyoming Supreme Court reviewed the case and found the district court did not err in denying the hospital district's motion for judgment as a matter of law. The court held there was sufficient evidence for a reasonable jury to find in favor of the personal representative on both direct and vicarious liability claims. The court also found the jury instructions adequately informed the jury of the applicable law and did not cause confusion.However, the Supreme Court determined the district court erred in reducing the damages. The jury found the CNA's conduct was negligent and that she was an agent of the hospital district, making the hospital district vicariously liable for her actions. The court reversed the judgment and remanded the case with instructions to enter a judgment for the full $660,000 in favor of the estate. View "Campbell County Hospital District v. Elsner" on Justia Law

Basecamp Teton WY SPV LLC (Basecamp) received a permit from the Wyoming Department of Environmental Quality (DEQ) to construct and operate a septic system for its glamping operation in Teton County, Wyoming. Protect Our Water Jackson Hole (POWJH), a nonprofit organization, sought a declaratory judgment claiming that DEQ lacked the authority to issue the permit due to a delegation agreement transferring permitting authority to Teton County. POWJH also requested an injunction to stay the permit during the litigation. The district court dismissed the complaint, citing several arguments from DEQ and Basecamp, including POWJH's lack of standing.The district court found that POWJH did not establish that a favorable decision would remedy any injury it suffered, as it was unclear whether Teton County would have denied the permit if Basecamp had applied there instead of to DEQ. The court also noted that POWJH was not a party to the delegation agreement and thus could not enforce it. POWJH's motion for reconsideration or to amend the complaint was denied, and the district court's dismissal was based on POWJH's lack of standing among other reasons.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision, focusing on POWJH's lack of standing. The court held that POWJH did not demonstrate a tangible interest that was harmed by DEQ's issuance of the permit. POWJH's allegations about its expenditures on water quality initiatives were deemed too vague and conclusory to establish a specific injury. Additionally, POWJH failed to show how the septic permit would directly harm its efforts or distinguish its interests from those of the general public. As a result, the court concluded that POWJH lacked standing to pursue the declaratory judgment action. View "Protect Our Water Jackson Hole v. Wyoming Department of Environmental Quality" on Justia Law

The Randy W. Stevens Living Trust owns land in Saratoga, Wyoming, bordered by an alleyway owned by the Town of Saratoga. Randy Stevens, the trustee, and Quality Landscape & Nursery, Inc., which uses the land, have had various disputes with the Town over the years. In 2019, a judgment was issued in favor of the Town, which the Stevens parties did not appeal. In 2023, the Stevens Trust and Quality Landscape filed a motion for an order to show cause and for a writ of mandamus, which the district court dismissed, citing res judicata and the parties' contractual limitations period. The court also found mandamus was not available under the circumstances.The district court of Carbon County had previously ruled on several issues between the parties, including the reconstruction of the alleyway, installation of utilities, and access to the property. The court found that the Town had acted in good faith and that the Stevens parties had failed to prove damages. The Stevens parties did not appeal these rulings. In 2023, they sought to revisit these issues, but the district court dismissed their motion, finding that the claims were barred by res judicata and the contractual limitations period.The Supreme Court of Wyoming reviewed the case and affirmed the district court's decision. The court held that the claims raised by the Stevens parties were barred by res judicata, as they had been or could have been litigated in prior proceedings. The court also agreed that mandamus was not an appropriate remedy, as the duties in question were not ministerial. Finally, the court found that judicial estoppel did not apply, as the Town had not taken inconsistent positions. The court affirmed the district court's dismissal of the Stevens parties' motion. View "Stevens v. The Governing Body of the Town of Saratoga, Wyoming" on Justia Law

In 2023, Basin Authority, a Wyoming Child Support Agency, notified Rodolfo P. Munoz that he was in arrears on his child support obligation and began garnishing his social security. Mr. Munoz filed a complaint against the State of Wyoming, the Wyoming Department of Family Services (DFS), and some of its employees, as well as Basin Authority and several of its employees. He alleged breach of contract and violations of due process under 42 U.S.C. § 1983. The district court dismissed Mr. Munoz’s complaint after a hearing.The district court of Big Horn County granted the motions to dismiss filed by the State Defendants and the Basin Authority Defendants. The court found that Mr. Munoz had not made allegations against the State Defendants and that they were not subject to suit under § 1983 because they are not “persons” within the meaning of the statute. The court also found that a breach of contract claim is not actionable under § 1983 and that the alleged agreement was void and unenforceable. Mr. Munoz’s objection and response to the State Defendants’ proposed order on the motion to dismiss and his motion for reconsideration were denied.The Supreme Court of Wyoming reviewed the case and summarily affirmed the district court’s decision. The court noted that Mr. Munoz failed to comply with the Wyoming Rules of Appellate Procedure and did not present cogent arguments supported by pertinent authority. The court emphasized that even pro se litigants must adhere to procedural rules and present coherent arguments. The court concluded that summary affirmance was appropriate due to the deficiencies in Mr. Munoz’s brief and his failure to present relevant legal arguments. View "Munoz v. State of Wyoming" on Justia Law

Harold Sheppard, Jr., who operates a plane salvage and trucking business, began leasing part of the South Big Horn County Airport in 2011 for a metal scrapping and recycling venture. In 2019, Big Horn County sued him for unpaid rent, resulting in a money judgment and an order to remove his property, which he did not comply with. In 2021, the County filed a $543,600 storage lien against his property. Sheppard then sued the Board of County Commissioners to stop the sale of his property, challenge the lien, and seek damages. The parties engaged in settlement negotiations in September 2022, leading to the vacating of a scheduled trial.The County Commissioners moved to dismiss Sheppard’s claims for failure to prosecute in January 2024, citing a lack of action since the September 2022 status conference. The district court granted the motion, dismissing the case with prejudice. Sheppard did not appeal this dismissal but filed a motion to reconsider under W.R.C.P. 60(b)(6) in March 2024, arguing that the dismissal was premature and that the court should enforce the settlement agreement before dismissing the case.The district court denied Sheppard’s motion, finding he failed to meet the burden for relief under Rule 60(b)(6). Sheppard appealed, arguing that the district court abused its discretion by not recognizing the unusual circumstances and the existence of a settlement agreement. The Wyoming Supreme Court reviewed the case and found that the district court did not abuse its discretion. The court noted that Sheppard failed to protect his legal interests by ensuring the settlement agreement and lease were executed and that his delay in filing the motion to reconsider was unreasonable. The Supreme Court affirmed the district court’s decision. View "Sheppard v. Board of County Commissioners, In and for Big Horn County, Wyoming" on Justia Law