Justia Wyoming Supreme Court Opinion Summaries

On November 25, 2023, a Casper Police Department officer conducted a welfare check on David Wayne Gober, who was found walking in the street. After determining Gober was not in distress, the officer ran his name and discovered an active warrant for failure to pay a fine. Upon arresting Gober, officers searched him and found glass pipes, jeweler’s bags containing a small amount of a crystal-like substance, metal tooter pipes, and unused syringes. The substances in the pipes and bags tested positive for methamphetamine. Gober was charged with felony possession of a controlled substance, methamphetamine, as it was a third or subsequent offense.The District Court of Natrona County presided over Gober’s jury trial. During the trial, Gober argued that the methamphetamine found was only a trace amount and proposed a de minimis infraction theory of defense instruction, which would allow the jury to acquit if the conduct was too trivial to warrant conviction. The district court refused to give this instruction, reasoning that Wyoming law does not set a minimum amount of methamphetamine for criminal liability and that the proposed instruction was not a recognized defense under Wyoming law. The jury found Gober guilty, and he was sentenced to two to four years’ imprisonment, suspended in favor of two years’ supervised probation.The Supreme Court of Wyoming reviewed the case. It held that the district court properly refused Gober’s proposed de minimis infraction instruction because Wyoming law criminalizes knowing or intentional possession of any amount of methamphetamine, regardless of quantity. The court found that the de minimis infraction defense is not recognized by Wyoming statute or case law for this offense and that the instruction would have improperly invited jury nullification. The Supreme Court of Wyoming affirmed the district court’s judgment. View "Gober v. State" on Justia Law

A woman and her long-term partner jointly purchased a duplex in Florida, signing both a promissory note and a mortgage as joint obligors and joint tenants with rights of survivorship. The note required monthly payments and a $100,000 balloon payment. After making all monthly payments, they failed to pay the balloon payment when due. The partner died shortly thereafter, and the woman became the sole owner of the property. The lender sent a default notice, and the woman entered into a forbearance agreement but did not pay the balloon payment. The lender filed a creditor’s claim against the deceased partner’s estate, which was rejected, leading the lender to sue the estate for the unpaid amount.The District Court of Fremont County, Wyoming, found the estate liable for the full balloon payment and associated costs, and also found the woman jointly liable as a co-obligor. The estate then sought contribution from the woman, arguing she should pay her share of the debt. After a bench trial, the district court determined that both the woman and the estate were each responsible for 50% of the balloon payment and related fees, applying Florida’s doctrine of equitable contribution. The court rejected the woman’s arguments that she should not be liable due to alleged inequitable conduct by the estate or because the deceased partner had intended to pay the balloon payment himself.On appeal, the Supreme Court of Wyoming reviewed the district court’s application of Florida law and its equitable determinations. The Supreme Court affirmed the lower court’s decision, holding that the woman was jointly liable for 50% of the balloon payment and associated costs. The court found no abuse of discretion in the district court’s application of the doctrine of equitable contribution, its rejection of the unclean hands defense, or its allocation of attorneys’ fees and costs. View "Hutton v. Dykes" on Justia Law

A law enforcement officer observed a black sedan at a busy intersection in Campbell County, Wyoming. The sedan, driven by Andrew Boyer, was in the right lane behind an SUV. When the light turned green, the SUV did not move, and Boyer overtook it on the right to turn east, remaining on the paved surface. The officer, concerned about the safety of this maneuver and suspecting a traffic violation, followed Boyer. While following, dispatch informed the officer that the vehicle’s registered owner, Boyer, did not have a valid driver’s license. After stopping Boyer, the officer confirmed his identity and learned he possessed a physical license, though the officer knew this did not guarantee valid driving privileges. During the stop, a K-9 unit alerted to drugs in the vehicle, leading to a search that uncovered methamphetamine, marijuana, and drug paraphernalia.Boyer was charged with several drug-related offenses and moved to suppress the evidence, arguing the stop was not supported by reasonable suspicion and that the scope of the stop was improperly expanded. The District Court of Campbell County denied the motion, finding the officer had reasonable suspicion both from observing the overtaking maneuver and from dispatch’s information about Boyer’s license status. The court also found the stop was not unnecessarily prolonged.On appeal, the Supreme Court of Wyoming reviewed whether the district court erred in denying the motion to suppress. The court held that the officer had reasonable suspicion to justify the initial stop based on both the observed traffic violation and the information from dispatch regarding Boyer’s license. The court concluded that the stop did not violate the Fourth Amendment, as the officer’s actions were reasonable under the totality of the circumstances. The Supreme Court of Wyoming affirmed the district court’s denial of the motion to suppress. View "Boyer v. The State of Wyoming" on Justia Law

A property owner purchased a lot in a Wyoming subdivision governed by two homeowners’ associations, each enforcing its own set of covenants. The owner sought to demolish an existing structure and build a new residence with an attached hangar, submitting construction plans for approval as required. Disputes arose over whether his application was complete and whether the associations unreasonably delayed or withheld approval, resulting in increased construction costs due to inflation. Complicating matters, one association (AVR I) had been dissolved years earlier, but its board continued to act as if it existed, later forming a new entity (AVR II) that purported to enforce covenants recorded after AVR I’s dissolution but before AVR II’s formal creation.The property owner initially sued AVR I, believing it to be the proper party, and later sued the other association, AAA. During discovery, he learned that AVR I had been defunct and that AVR II was the actual entity acting as the homeowners’ association. He moved to amend his complaint to add AVR II and assert new claims, including that the covenants were invalid. The District Court of Lincoln County denied the motion to amend, finding the amendments would be futile, and granted summary judgment to AVR I, reasoning that the covenants automatically approved the owner’s plans by default and any delay was self-imposed.The Supreme Court of Wyoming reviewed the case and held that the district court abused its discretion in denying leave to amend the complaint. The Supreme Court found that the proposed claims against AVR II were not futile, as there were unresolved factual and legal questions regarding the validity and enforceability of the covenants and AVR II’s authority. The court also held that summary judgment for AVR I was premature. The orders denying amendment and granting summary judgment were reversed, and the case was remanded for further proceedings. View "Conger v. AVR Homeowner's Association, Inc." on Justia Law

The dispute centers on whether the trustees of a family trust, who inherited land south of a subdivision, have an easement—either express or implied—across Lot 4 of the subdivision, now owned by the Fullers. The subdivision, created by the Clarks’ predecessor, included a private road (Buttercup Lane) running north-south through all four lots, ending at a temporary cul-de-sac at the southern edge of Lot 4. The original owner reserved the right to extend the road to the southern boundary for access to adjoining lands, contingent on providing notice to Lot 4’s owners. After the Fullers purchased Lot 4 and denied access, the trustees sued, claiming an easement for access to their southern property.The District Court of Lincoln County held a bench trial and found that no express easement existed because the original owner had not exercised her reserved right by providing the required notice to Lot 4’s owners. The court also found no implied easement, concluding that the trustees failed to show that access through Lot 4 was necessary and beneficial, as alternative access routes to the southern property existed. The trustees appealed these findings.The Supreme Court of Wyoming reviewed the district court’s factual findings for clear error and its legal conclusions de novo. The Supreme Court affirmed the district court’s decision, holding that the evidence did not show the required notice was given to create an express easement, and that the existence of alternative access routes meant the necessity element for an implied easement was not met. The Supreme Court of Wyoming thus affirmed the judgment, finding no express or implied easement across Lot 4 in favor of the trustees. View "Clark v. Fuller" on Justia Law

Kenneth Minshall sought to quiet title to a two-acre property in Washakie County, Wyoming, which had previously belonged to Gail Lee Quinn. Minshall lived with Quinn for decades and claimed that Quinn had agreed to transfer the property to his business, identified variously as M/G Enterprises, M/Q Enterprises, or M-Q Enterprises, all sharing the same EIN but none of which were ever legally incorporated. In 2018, Quinn executed a quitclaim deed purporting to transfer the property to M/G Enterprises. After Quinn’s death in 2019, Minshall executed a quitclaim deed on behalf of M/G Enterprises to himself. Quinn’s daughters, Robin Griffin and Joy Osbon, as her heirs and personal representatives, contested Minshall’s claim to the property.The District Court of Washakie County held a bench trial and found that the deeds purporting to transfer the property to M/G Enterprises (or its variants) were void because the grantee entities had no legal existence and thus could not take title. The court concluded that the last valid deed left the property in Quinn’s name, making it subject to probate by her estate. The court ordered that the void deeds be stricken from the county records. Minshall appealed, arguing that the doctrine of estoppel by deed should prevent Quinn’s heirs and estate from challenging the validity of the deeds.The Supreme Court of Wyoming affirmed the district court’s decision. It held that estoppel by deed cannot apply where the underlying deed is void, as a deed to a nonexistent entity is a nullity and does not pass title. Because the grantee entities never legally existed, no interest in the property was conveyed, and the property remained with Quinn’s estate. The court affirmed that the doctrine of estoppel by deed had no application in this case. View "Minshall v. Griffin" on Justia Law

Between 2017 and 2023, a woman applied for and received welfare benefits for herself and her three children under three government programs: SNAP, Medicaid, and LIEAP. During this period, she did not list the children’s father as a household member on any of her applications, despite evidence that they lived together. She also failed to disclose several assets, including joint bank accounts, a timeshare, and other real property. An investigation by the Wyoming Department of Family Services revealed these omissions, leading to criminal charges.The State of Wyoming charged her with nineteen counts of welfare fraud, alleging that she knowingly made false statements or omitted material facts on her benefit applications, with each count involving benefits exceeding $500. The case proceeded to a bench trial in the District Court of Carbon County, where the State presented documentary evidence and witness testimony showing the woman and the children’s father shared addresses, held themselves out as a married couple, and jointly owned assets. The district court found her guilty on eighteen counts, concluding she knowingly misrepresented her household composition and failed to disclose assets, which affected her eligibility for benefits. She was sentenced to a split sentence of jail time and probation, with restitution ordered.On appeal, the Supreme Court of Wyoming reviewed whether the evidence was sufficient to support the convictions. Applying the standard that requires viewing the evidence in the light most favorable to the State, the court held that there was ample evidence for the district court to reasonably conclude the woman knowingly omitted the children’s father as a household member and failed to disclose joint assets. The Supreme Court of Wyoming affirmed the convictions for eighteen counts of welfare fraud. View "Fitzwater v. State" on Justia Law

Several individuals formed a corporation, each contributing initial capital and later making additional cash contributions to meet the company’s needs. These later contributions were documented as promissory notes, including three notes issued to one founder, which were subsequently held by a trust after his death. The notes specified a 24-month term, a fixed interest rate, and repayment terms, but did not explicitly state they were payable on demand. After the founder’s death, the trust demanded payment on the notes, but the company refused, arguing the notes were not yet due, were actually capital contributions, or were subordinate to other shareholder loans.The District Court of Albany County dismissed claims by other shareholders seeking priority repayment, finding no justiciable controversy, and resolved the remaining issues on summary judgment. The court determined the notes were loans, not capital contributions, and that all founders’ notes should be repaid equitably if any were repaid. However, it found the notes were not immediately due and payable, as they lacked a demand provision, and denied the trust’s request for immediate payment. The court did award attorney fees to the trust under the terms of the notes.The Supreme Court of Wyoming reviewed the case and reversed the district court’s finding that the notes were not due and payable, holding that the notes matured after 24 months and were enforceable at that time. The court affirmed that the notes were loans, not capital contributions, and declined to give priority to other shareholder loans, finding no contractual basis for subordination. The court also affirmed the award of attorney fees to the trust and upheld the dismissal of the other shareholders’ claims for lack of a justiciable controversy. The case was remanded for entry of judgment in favor of the trust and determination of reasonable attorney fees and costs. View "King v. Sheesley" on Justia Law

Burke McCarthy died in October 2018 after receiving medical treatment from Dr. Wesley Hiser at Wyoming Medical Center. Dianna Ellis, McCarthy’s daughter and wrongful death representative, filed a wrongful death lawsuit against Dr. Hiser and the hospital in February 2021, within the two-year statute of limitations. However, Dr. Hiser was never served with the original complaint. Nearly two years later, Ellis voluntarily dismissed her suit against Dr. Hiser. In December 2023, she refiled her complaint, relying on Wyoming’s savings statute to argue she had an additional year to commence a new action. Dr. Hiser was served for the first time in February 2024, more than five years after McCarthy’s death.The District Court of Natrona County granted Dr. Hiser’s motion to dismiss the refiled complaint. The court found that it had never obtained jurisdiction over Dr. Hiser in the original action because he was not served, and therefore the savings statute could not apply to extend the time for refiling. Ellis appealed this decision.The Supreme Court of Wyoming reviewed the case de novo. The court held that Wyoming’s savings statute, Wyo. Stat. Ann. § 1-3-118, does not apply to actions that are voluntarily dismissed by the plaintiff. The court overruled its prior decision in Hugus v. Reeder, 2022 WY 13, which had held that a voluntary dismissal qualified as a “failure otherwise than upon the merits” under the savings statute. The court reasoned that a voluntary dismissal is not a “failure” within the meaning of the statute, as it is a matter of choice rather than an unsuccessful attempt to proceed. Accordingly, the Supreme Court of Wyoming affirmed the district court’s dismissal of Ellis’s refiled complaint. View "Ellis v. Hiser" on Justia Law

Robert Redland's parents accumulated ranching property in the Big Horn Basin, which Robert and his wife, Irene, later purchased. They raised their five children on these properties and created the Robert and Irene Redland Family Trust in 1989 to manage the ranch properties. Robert promised his children that all ranch properties would be placed in the trust, except for the Manderson Place, which would be placed in the trust after his and Irene's deaths. In 2007, Robert and Irene sold an 11-acre parcel of the Manderson Place to their daughter Lisa and her husband, Mike Kimsey. The Redland Children discovered that the Manderson Place and other properties were not in the trust and sued Robert and the Kimseys.The District Court of Big Horn County initially ruled that Robert must transfer the disputed properties to the trust, including the 11 acres sold to the Kimseys. However, the court later amended its judgment, removing the requirement for the 11 acres to be transferred to the trust, as the Redland Children had not stated a claim against the Kimseys for the return of the 11 acres. The Redland Children did not appeal this amendment.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision, except for the provision regarding the Manderson Place, which it ordered to be transferred to the trust immediately, subject to a life estate in Robert. The district court then issued a judgment excluding the 11 acres from the trust, which the Redland Children appealed.The Wyoming Supreme Court held that its previous decision did not require the 11 acres to be transferred to the trust and that the district court did not abuse its discretion in denying the Redland Children's motions to amend their complaint and for attorney fees. The court affirmed the district court's judgment exempting the 11 acres from being transferred to the trust. View "Redland v. Kimsey" on Justia Law