Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of Security State Bank (SSB) on Plaintiff's claims and SSB's breach of contract counterclaim, holding that there was no error.When Plaintiff defaulted on several agricultural loans she had obtained from SSB, SSB foreclosed on some of the collateral Plaintiff pledged to secure those loans. Plaintiff then brought this action, alleging, among other things, negligent lending and negligent advising. SSB counterclaimed, alleging, among other things, breach of contract. The district court granted summary judgment in favor of SSB on all claims. The Supreme Court affirmed, holding (1) this Court declines to recognize new causes of action for negligent lending or negligence advising; (2) there were no questions of material fact barring summary judgment on Plaintiff's breach of good faith and fair dealing claim; and (3) the district court did not err in finding that equitable defenses did not preclude entering summary judgment in favor of SSB on his counterclaim for breach of contract. View "Wilcox v. Security State Bank" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Father's petition to modify a child custody order granting Mother primary custody of the parties' daughter (Child), holding that there was no abuse of discretion during the proceedings below.The original child custody order granted Mother primary custody of Child. Father later petitioned the court to modify the order, claiming that the original order had proved unworkable due to ambiguity in its terms. After a trial, the district court concluded that a material change of circumstances had occurred since the original order and that it was in Child's best interests for the parties to have shared custody. The Supreme Court affirmed, holding that there was no abuse of discretion in the district court's conclusion that there had been a material change of circumstances affecting Child's welfare since the original custody and visitation order and that Child's best interests would be served by granting the parties shared custody. View "Gardels v. Bowling" on Justia Law

In this divorce action, the Supreme Court affirmed the judgment of the district court in all respects, holding that the district court did not abuse its discretion its division of the parties' marital property.On appeal, Wife challenged the district court's division of marital property, arguing that the district court abused its discretion in its calculation of the equalization payment due to Wife from Husband. The Supreme Court affirmed, holding (1) Wife failed to demonstrate clear grounds for altering the property distribution; and (2) the court's disposition of the marital estate was neither so unfair nor so inequitable that it was unreasonable. View "D'Anzi v. D'Anzi" on Justia Law

The Supreme Court affirmed the decision of the district court granting Father's petition to modify the parties' divorce decree by awarding Father primary physical custody of the children and restricting Mother's visitation with the children, holding that there was no abuse of discretion.On appeal, Mother argued, among other things, that the district court abused its discretion by suspending her right to overnight visitation with the children for part of the time the modification action was pending. The Supreme Court affirmed, holding (1) the district court did not err in awarding primary physical and sole legal custody of the parties' two children to Father; and (2) Mother was not entitled to relief on her remaining allegations of error. View "Baer v. Baer" on Justia Law

The Supreme Court affirmed the decision of the district court affirming the ruling of the district court affirming the decision of the Medical Commission upholding the order of the Department of Workforce Services denying Appellant's application for permanent total disability benefits under the odd-lot doctrine, holding that there was no error.On appeal, Appellant argued that substantial evidence did not support the Commission's determination that he failed to show his degree of obvious physical impairment, coupled with other facts, qualified him for odd-lot treatment. The Supreme Court affirmed, holding (1) Appellant failed to meet his burden to establish a degree of physical impairment; and (2) the Commission's credibility determinations were not arbitrary and capricious. View "Rodriguez v. State ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing this action brought by Sweetwater Station, LLC (Sweetwater) against the Sweetwater Station Homeowners Association (HOA) in this dispute over the covenants, conditions, and restrictions (CCRs) applicable to the subdivision Sweetwater Station Addition, holding that the district court erred in dismissing Sweetwater's claims.In 2020, the HOA unilaterally recorded an amendment to the CCRs that affected the rights of the declarant, Sweetwater. Sweetwater sued the HOA and its members, seeking a declaration that the amendment was invalid and also asserting claims for quiet title, slander of title, and interference with a prospective contract. The district court dismissed the complaint for failure to state a claim after finding that the amendment to the CCRs was valid. The Supreme Court reversed, holding (1) the district court erred in dismissing Sweetwater's declaratory judgment and quiet title claims because the amendment provisions of the CCRs were ambiguous, requiring extrinsic evidence to determine the parties' intent; and (2) Sweetwater adequately pled its claims for slander of title and interference with a prospective contract. View "Sweetwater Station, LLC v. Pedri" on Justia Law

In this divorce action, the Supreme Court affirmed the judgment of the district court denying Husband's motions to continue the bench trial and the court's division of marital property, holding that the district court did not abuse its discretion.After seventeen years of marriage, the parties in this case divorced. Husband appealed, arguing, among other things, that the district court abused its discretion and violated his constitutional due process in denying his motions to continue the trial. The Supreme Court affirmed, holding that the district court (1) did not deny Husband due process by denying Husband's motions to continue; and (2) did not abuse its discretion in its division of marital property and debts. View "Engebretsen v. Engebretsen" on Justia Law

The Supreme Court affirmed the judgment of the district court reducing Joshua Anderle's sentence for sexual abuse of a minor by two years following his completion of the Youthful Offender Transition Program, holding that the district court did not abuse its discretion by reducing Anderle's sentence by two years in recognition of his successful completion of the program.Anderle entered an Alford plea to second-degree sexual abuse of a minor. The district court sentenced him to eight to twelve years' imprisonment and recommended that the Wyoming Department of Corrections treat Anderle as a youthful offender under Wyo. Stat. Ann. 7-13-1001 et seq. After Anderle successfully completed the program the court held a sentence reduction hearing and reduced Anderle's sentence by two years. The Supreme Court affirmed, holding that the district court reasonably declined to reduce Anderle's sentence to probation. View "Anderle v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of two counts of aggravated assault for attempting to cause harm to others after he led law enforcement on a high-speed chase and nearly collided with with a patrol car occupied by a law enforcement officer, holding that the record was unclear as to the state of Defendant's second aggravated assault conviction.At issue on appeal was whether the district court abused its discretion when it instructed the jury that attempted aggravated assault under Wyo. Stat. Ann. 6-2-502(a)(i) could be committed knowingly. The Supreme Court reversed Defendant's convictions, holding (1) the legislature did not intend to create a general intent attempt crime when it defined attempted aggravated assault; and (2) a jury instruction and verdict form did not provide the "jury a correct and legally sufficient basis" upon which to convict Defendant. The Court remanded the case for clarification and resentencing, if necessary. View "Schuerman v. State" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment to Plaintiff on his claim of adverse possession of one-tenth of an acre of Defendants' property, holding that the district court did not err or abuse its discretion.On appeal, Defendants argued that Plaintiff could not show adverse possession because there was a factual question as to whether Plaintiff's use of the property was permissive under the theory of neighborly accommodation. The Supreme Court disagreed and affirmed, holding (1) Plaintiff established a prima facie claim of adverse possession which Defendants failed to rebut; and (2) there was no genuine issue of material fact, and the district court did not err in granting summary judgment to Plaintiff. View "Kudar v. Morgan" on Justia Law