Justia Wyoming Supreme Court Opinion Summaries

In the case before the Supreme Court of Wyoming, State Representatives Rachel Rodriguez-Williams and Chip Neiman, and Right to Life of Wyoming, Inc., attempted to intervene in a lawsuit challenging the constitutionality of two Wyoming laws restricting abortion. The district court denied their motion to intervene, and they appealed that decision. The Supreme Court of Wyoming affirmed the lower court's decision, holding that the proposed intervenors did not meet the requirements for intervention as of right. The court found that the proposed intervenors did not demonstrate a significant protectable interest in the lawsuit. The court also found that the State of Wyoming, represented by the Attorney General, adequately represented the proposed intervenors' interests in defending the challenged laws. Additionally, the court found that allowing the proposed intervenors to participate in the lawsuit would unduly delay and prejudice the case's adjudication. Therefore, the court also denied the proposed intervenors' motion for permissive intervention. View "Rodriguez-Williams v. Johnson" on Justia Law

The Supreme Court of Wyoming upheld the conviction of Charles Anthony "Tony" Santistevan for multiple counts of sexual assault and one count of voyeurism. The court found that the district court did not abuse its discretion when it allowed the state to introduce evidence that Santistevan's sexual relationship with the victim, R.S., began when she was a minor. This evidence was introduced under the Wyoming Rules of Evidence (W.R.E.) 404(b), which allows evidence of other crimes, wrongs, or acts for certain purposes, such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident. Santistevan argued that the introduction of this evidence was an abuse of the district court's discretion, but the Supreme Court disagreed. It held that the evidence was relevant and admissible under W.R.E. 404(b) to show an ongoing scheme or plan and to demonstrate Santistevan's course of conduct, and to provide a complete story to the jury about the relationship between Santistevan and R.S., thereby aiding in determining the issue of consent in the sexual assault charges. View "Charles A. Santistevan v. The State of Wyoming" on Justia Law

In this case, the appellant, Bjay Nagel, who was employed as a caretaker by Sand Creek Country Club, broke his ankle while working. He had been drinking alcohol prior to the accident. The Wyoming Department of Workforce Services, Workers' Compensation Division initially awarded benefits but later denied further benefits after discovering that Nagel was intoxicated at the time of his injury. The Wyoming Office of Administrative Hearings (OAH) upheld the Division's denial of benefits, finding that Nagel's intoxication was a substantial factor causing his injury. Nagel appealed the decision, claiming that the OAH's decision was contrary to substantial evidence, arbitrary, capricious, or otherwise not in accordance with the law.The Supreme Court of Wyoming affirmed the decision of the lower court. The Court found that there was substantial evidence supporting the OAH's decision that Nagel's intoxication was a substantial factor causing his injury. The Court also found that the decision was not arbitrary or capricious because there was a rational basis for it, and the decision was in accordance with the law. Nagel's intoxication at the time of his injury was established by a blood alcohol content test which showed a level of .183%. Furthermore, an expert opinion was provided which stated that it was more likely than not that Nagel's intoxication was a substantial factor causing his injury. View "Nagel v. State of Wyoming, Ex Rel. Department of Workforce Services" on Justia Law

In this case, the City of Laramie, Wyoming, sued the University of Wyoming and its Board of Trustees, challenging the drilling and operation of certain water wells. The city argued that the university was in violation of a 1965 deed covenant prohibiting the drilling of one of the wells and was also in violation of a city ordinance. The city also claimed that legislation exempting the university from this city ordinance was unconstitutional. The district court dismissed some of the city's claims and granted summary judgment in favor of the university on the remaining claims. The Supreme Court of Wyoming affirmed the lower court's decision. The court held that the university was protected by sovereign immunity from the city's attempts to enforce the deed covenant. It also held that the state law exempting the university from the city ordinance was constitutional. The court further noted that the law precluded the city from enforcing its ordinance against the university. View "City of Laramie, Wyoming v. University of Wyoming" on Justia Law

In this case from the Supreme Court of Wyoming, LFP Consulting, LLC (LFP), a financial advisory company, sued former employee David Edward Leighton for breach of contract and various torts after his resignation. The key issue was a clause in the parties' contract that selected Minnesota as the forum for disputes (a forum selection clause). LFP had filed the lawsuit in Wyoming and attached a waiver of the forum selection clause. However, the Wyoming chancery court dismissed LFP’s complaint for improper venue, concluding that LFP did not have the right to unilaterally waive the forum selection clause. The Supreme Court of Wyoming disagreed with the lower court, ruling that LFP, as the assignee of the contract, had the right to unilaterally waive the forum selection clause because it was included in the contract for the sole benefit of Ameriprise Financial, the original party to the contract with Leighton. The court also noted that Leighton had no relationship with Minnesota, which further supported the decision to allow LFP to waive the forum selection clause. The court reversed the decision of the chancery court and remanded the case for further proceedings. View "LFP Consulting, LLC v. Leighton" on Justia Law

In the case before the Supreme Court, State of Wyoming, the Petitioners, Kenneth Carson and Anna Leigh Anderson, parents of two children living in a remote family ranch in Wyoming, sought to compel the Albany County School District Board of Trustees, the Superintendent of Schools for Albany County, and the Superintendent of Public Instruction for the State of Wyoming (collectively, Respondents) to establish a rural school, named "The Buckle School," on their ranch. The proposal for this school was initially approved by the Albany County School District Board of Trustees and the Director of the State Construction Department. However, the State Superintendent of Public Instruction later denied the approval, citing the cost-effectiveness of the proposed school and the availability of virtual education options for the children.The Petitioners then filed a petition for a writ of mandamus in the district court, which was dismissed. Upon appeal, the Supreme Court, State of Wyoming, affirmed the lower court's decision. The court held that the Petitioners failed to demonstrate that the Respondents had a ministerial duty to form the school. A ministerial duty is a duty that is absolute, clear, and indisputable, involving merely execution of a specific duty arising from fixed and designated facts. The court found that the relevant statutes provided the Respondents with discretionary judgment, not a ministerial duty to approve or deny the formation of a rural school. The court further noted that the Petitioners had not shown that they had requested or were denied any transportation or maintenance payments, which the relevant statutes provide for in lieu of establishing a school. Therefore, the court concluded that the Petitioners had failed to state a claim upon which mandamus relief could be granted. View "Carson v. Albany County School District #1 Board of Trustees" on Justia Law

In this case, Shaun T. Kobielusz appealed his convictions of three counts of voyeurism. Kobielusz contended that there was insufficient evidence of the element of “looking” for the jury to convict him of voyeurism, that the jury instruction given on the elements of voyeurism was improper, and that the district court erred when it denied his motion to suppress videos on a memory card given to law enforcement by his wife. The Supreme Court of Wyoming disagreed with Kobielusz's claims. They determined that the voyeurism statute does not require proof of “looking” at the captured images for a conviction. They also found that the jury instruction did not violate a clear and unequivocal rule of law. Lastly, they affirmed the district court's decision to deny Kobielusz's motion to suppress the videos, concluding that his wife had common authority over the memory cards and had the right to consent to their search. Therefore, the court affirmed Kobielusz's conviction. View "Kobielusz v. Wyoming" on Justia Law

In Wyoming, Darrell R. Turcato and Robbin D. Wilkins (Appellants) and Jan Frady and Larry Turcato (Petitioners) were beneficiaries of two trusts created by their parents. The Appellants sought to appeal the district court's decision that a warranty deed executed by the Trusts transferring property to them was invalid due to a defective acknowledgment. The property in question was a house, which was held 50% by the JT Trust and 50% by the VT Trust. The mother, Virginia Turcato, decided to transfer the house to the Appellants in recognition of their assistance. However, her signature was notarized outside her presence. After her death, the Petitioners sought a declaration that the transfer was invalid due to the defective acknowledgment. The district court determined that the Petitioners, as beneficiaries of the trusts, had an interest in the property when the deed was executed and therefore declared the warranty deed void against them.The Wyoming Supreme Court reversed the district court's decision. The Court held that a defective acknowledgment does not render a warranty deed void ab initio under Wyoming law. It found that when the parties signed the Warranty Deed, title immediately passed to Appellants, and that title was valid against all but certain parties. The Court also held that the Petitioners did not have an interest in the property at the time of the transfer and therefore had no standing to challenge the Warranty Deed. The Court concluded that the Warranty Deed is valid between the Trusts and the Appellants, and remanded the case to the district court for dismissal. View "Turcato v. Frady" on Justia Law

The case revolves around Leopoldo Alvarado, who sought to terminate his duty to register as a sex offender after having registered for at least ten years, pursuant to Wyo. Stat. Ann. § 7-19-304 of the Wyoming Sex Offender Registration Act. The District Court denied his petition on the grounds that the time he spent on probation did not count toward the ten-year statutory prerequisite.However, the Supreme Court of the State of Wyoming disagreed and reversed the decision of the District Court. The Supreme Court found that the clear and unambiguous language of Wyo. Stat. Ann. § 7-19-304 does not require probation to be completed before the ten-year registration period begins to run. The court ruled that probation is not listed as a tolling event, and the court will not read words into a statute when the legislature has chosen not to include them.The Supreme Court stated that the District Court should have considered whether Mr. Alvarado should be relieved of the duty to continue registration after demonstrating he had maintained a clean record by meeting all four conditions during the ten-year registration period. These conditions included having no conviction of any offense for which imprisonment for more than one year may be imposed, having no conviction of any sex offense, successfully completing any periods of supervised release, probation, and parole, and successfully completing any sex offender treatment previously ordered by the trial court or his probation or parole agent. The case was remanded for further consideration. View "Alvarado v. State" on Justia Law

In the Supreme Court of the State of Wyoming, the appellant, Rachel E. Bennett, appealed a district court decision that held her in contempt of court for failing to adhere to several provisions of a divorce decree. The decree involved her ex-spouse, Matthew J. Bennett, and outlined certain responsibilities concerning their two minor children. These responsibilities included equally sharing uninsured medical expenses for their children, following all medical directives regarding the children's health, and consulting each other before making any non-emergency decisions about the children's health, education, or welfare.The district court found Rachel in contempt for failing to pay her half of the uninsured medical bills, not adhering to medical directives for their oldest child, and reengaging the children in counseling without seeking Matthew's advice or consent. The Supreme Court of Wyoming affirmed the district court's decision, finding no error in the lower court's judgment that Rachel had willfully disobeyed the provisions of the decree. They held that the district court did not abuse its discretion in its findings, and that it could reasonably conclude as it did based on the testimony presented by both parties. View "Bennett v. Bennett" on Justia Law