Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court reversed Defendant's conviction for misdemeanor interference with a peace officer stemming from his act of resisting when police officers entered his home without a warrant to arrest him for a misdemeanor crime, holding that, under the circumstances of this case, Defendant's conviction could not stand.On appeal, Defendant argued that the officers' warrantless entry into his home was unlawful, and therefore, the trial court erred in denying his motion to suppress. The Supreme Court reversed, holding (1) the officers in this case were not "engaged in the lawful performance" of their official duties when they entered Defendant's home without a warrant, as required to convict him under Wyo. Stat. Ann. 6-5-204(a); and (2) because the officers' warrantless entry into Defendant's home was per se unreasonable, the warrantless entry into Defendant's home to execute a warrantless arrest violated Defendant's rights under the Fourth Amendment. View "Woods v. State" on Justia Law

The Supreme Court accepted certification of a question from the district court regarding the authority of a court-appointed guardian and conservator of an incompetent adult ward to petition the district court for the ward's divorce and concluded that neither a guardian nor a conservator has the power under Wyoming law to pursue a divorce on behalf of a ward.Guardian/Conservator, who was appointed as guardian of Madonna Flory's person and conservator of her estate, filed a complaint for Ms. Flory's divorce from Rand Flory. The parties agreed that there was no controlling Wyoming precedent on the issue of whether a guardian or conservator could file for divorce on behalf of a ward, and the district court certified the question to the Supreme Court. In response the Supreme Court answered that Wyoming law does not permit a a guardian or conservator to move for and prosecute a divorce action on behalf of the ward. View "Flory v. Flory" on Justia Law

The Morningstars contracted to purchase a residential property from the Robisons, who intended to buy a nearby vacant lot and build a new house. When the lot they wished to buy was purchased by someone else, the Robisons failed to comply with the terms of the contract with the Morningstars. The Morningstars sought specific performance and monetary damages. The district court found the Robisons breached the contract, but denied the request for specific performance and awarded monetary damages.The Wyoming Supreme Court reversed. The district court erred in placing the burden on the Morningstars to prove monetary damages were an inadequate or impractical remedy and abused its discretion when it found specific performance was not an appropriate remedy. After finding only one of the special equities factors weighed in favor of the Robisons, the court essentially rewrote the contract to allow the Robisons to cancel because their preferred lot was unavailable. The Robisons admit they “had no legal recourse to cancel.” On remand, when determining if any monetary damages should be awarded in addition to specific performance, the court’s “guiding principle” should be to relate the contract back to August 2021, and place the Morningstars in as nearly the same position as they would have been in if the Robisons had not breached the contract. View "Morningstar v. Robison" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of stalking his ex-wife, holding that Defendant was not denied his right to a speedy trial and that the trial court did not commit prejudicial error in instructing the jury.After a jury trial, Defendant was found guilty of one count of felony stalking and sentenced to four to six years in prison. The Supreme Court affirmed, holding (1) Defendant was not denied his right to a speedy trial under either Wyo. R. Crim. P. 48 or the Sixth Amendment to the United States Constitution; and (2) the district court abused its discretion by giving instruction number fourteen because it described stalking as a general intent crime when it, in fact, is a specific intent crime, but Appellant did not meet his burden to demonstrate prejudice. View "Person v. State" on Justia Law

The Supreme Court dismissed in part and reversed in part the orders of the probate court and district court in these probate and partition matters, holding that remand was required.Dwight and Betty Lyman, as Trustees of their living trust (Lyman Trust), owned a parcel of property as tenants in common with George Fisher and another parcel in common with George's deceased parents. George sold his parents' interests in the two parcels to the Childs Trust. Lyman Trust filed a petition in the district court seeking to partition the parcels and filed a motion in the probate court seeking to set aside the sale. The probate court denied the motion, and the district court dismissed the partition petition without prejudice for failure to join Childs Trust as a required party. The Supreme Court (1) dismissed Lyman Trust's appeal of the probate court's actions, holding that Lyman Trust lacked standing in the Fisher probate action; and (2) reversed the district court's judgment dismissing Lyman Trust's partition action, holding that the court erred by dismissing the action rather than ordering the joinder of Childs Trust, and dismissal was not harmless. View "Lyman v. Fisher" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Mother's request for a jury trial in this termination of parental rights case, holding that the district court exercised sound judgment under the circumstances.The Department of Family Services brought an action to terminate Mother's parental rights to her son. Mother failed to make a timely demand for a jury trial pursuant to Wyo. R. Crim. P. 38 (Rule 38) and later requested that the district court grant a jury trial under Wyo. R. Crim. P. 39(b). The district court denied Mother's request and subsequently terminated her parental rights. The Supreme Court affirmed, holding (1) the order denying Mother's Rule 39 motion was not a final appealable order; and (2) the district court did not abuse its discretion in denying Mother's request for a jury trial. View "Gipson v. State, ex rel. Dep't of Family Services" on Justia Law

The Supreme Court reversed Defendant's conviction for two counts of forgery, holding that the district court plainly erred in accepting Defendant's guilty plea because it lacked a factual basis.Defendant was charged with two felony counts of forgery, in violation of Wyo. Stat. Ann. 6-3-602(a)(ii). Defendant pled guilty to both counts pursuant to a plea agreement. The district court found the plea voluntary, accepted the factual basis, and sentenced Defendant. The Supreme Court reversed, holding (1) the district court violated a clear and unequivocal rule of law when it accepted Defendant’s guilty plea without having a sufficient factual basis to conclude that she committed forgery under Wyo. Stat. Ann. § 6-3-602(a)(ii); and (2) Defendant suffered material prejudice when the district court sentenced her to a crime that the record did not reflect she committed. View "Delarosa v. State" on Justia Law

The Supreme Court reversed the decision of the district court denying Wife's motion for relief filed under Wyo. R. Crim. P. 60(a) from a divorce decree entered in 2003, holding that the district court erred as a matter of law in denying Rule 60(a) motion.At issue was the provision in the parties' stipulated decree of divorce that granted Wife fifty percent of the marital portion of Husband's disposable retired pay under his military retirement plan and provided a formula to calculate the marital portion based on Husband's months of service. In her Rule 60(a) motion, Wife argued that the formula's use of the word "months" rather than the term "reserve points" prevented her from collecting her share of Husband's military retired pay. The Supreme Court agreed and reversed the district court's denial of Wife's motion for relief, holding that the decree's use of "months" instead of "reserve points" was a clerical mistake requiring correction. View "Stone v. Stone" on Justia Law

The Supreme Court affirmed the order of the district court granting the petition brought by the Wyoming Department of Family Services (DFS) to terminate the parental rights of Mother to her child, holding that Mother was not entitled to relief on her claims of error.After a hearing, the district court held that the Department of Family Services (DFS) had presented clear and convincing evidence that Mother's parental rights to her child should be terminated under Wyo. Stat. Ann. 14-2-309(a)(iii) and (a)(v). The court further held that termination would be in the child's best interest. The Supreme Court affirmed, holding that the record supported the district court's holding that DFS made reasonable but unsuccessful efforts to rehabilitate and reunify Mother and her child under Wyo. Stat. Ann. 14-2-309(a)(iii). View "Alcorn v. State ex rel. Dep't of Family Services" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Felix Felicis, LLC's (Felix) application to vacate an arbitrator award in favor of Riva Ridge Owners Association (RROA) in this dispute over annual assessments, holding that the district court did not err in denying the application.This litigation arose after RROA's site committee rejected Felix's plans to build a home on its tract in the Riva Ridge subdivision. The attorney fees and costs RROA incurred during the litigation RROA ratably levied upon all tract owners in the subdivision via annual assessments. Felix refused to pay a portion of them based on its belief that RROA was not authorized by the restrictive covenants to assess attorney fees and costs against the tract owners. Felix later submitted its dispute with RROA to binding arbitration. The arbitrator granted summary judgment for RROA and awarded it a total of $334,890. Felix moved to vacate the arbitration award on the grounds that the arbitrator exceeded his powers by failing to consider Felix's affirmative defenses. The district court denied the application. The Supreme Court affirmed, holding that Felix failed to show by clear and convincing evidence that the arbitrator made a manifest mistake of the law in granting summary judgment for RROA. View "Felix Felicis, LLC v. Riva Ridge Owners Ass'n" on Justia Law