Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court setting aside Resolution 2077, which was adopted by the Campbell County Board of Commissioners in 2021, holding that there was no error.Resolution 2077 "revoked and superseded" previous resolutions approving Petitioners - Wyoming Horse Racing, LLC and Wyoming Downs, LLC - to conduct simulcast operations under Wyo. Stat. Ann. 11-25-102(a)(vii)(B) and placed conditions on all future approvals. Petitioners filed a petition for judicial review, arguing that the resolution exceeded the statutory authority of Campbell County under the Wyoming Pari-Mutuel Act, Wyo. Stat. Ann. 11-25-101 et seq. The Supreme Court affirmed, holding that the County had authority under the Pari-Mutuel Act to revoke its prior approvals of Petitioners' simulcast operations. View "Campbell County Bd. of Commissioners v. Wyo. Horse Racing, LLC" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of felony domestic battery, holding that the district court did not commit prejudicial error in admitting uncharged misconduct evidence without proper notice and a Wyo. R. Evid. 404(b) hearing.After Defendant was arraigned, the district court issued an order directing the State to provide Defendant notice of any Rule 404(b) evidence it intended to use at trial. The State provided no such notice. During trial, the State told the jury in of an uncharged incident and elicited testimony from the alleged victim about the incident. The Supreme Court held (1) the State failed in its obligation to provide notice of the Wyo. R. Evid. 404(b) evidence it intended to use at the criminal trial, and the district court erred by admitting the evidence; but (2) Defendant was not prejudiced by the admission of the unnoticed Rule 404(b) evidence. View "Olson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony strangulation of a household member and misdemeanor false imprisonment, holding that the district court did not err or abuse its discretion in the proceedings below.On appeal, the Supreme Court held that the district court (1) did not err by concluding that the affidavit in support of the search warrant to search Defendant's cellular phones, his place of employment, his work truck, and his person for certain documents, including journals, established probable cause to search and seize Defendant's journals and in thus denying Defendant's motion to suppress; and (2) did not abuse its discretion at sentencing by considering conduct for which Defendant was acquitted. View "Kreusel v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court in favor of Defendants in this negligence case, holding that the district court did not err or abuse its discretion.Mike Roberts was injured at the home of his son, Benjamin Roberts, when he stepped off the edge of the back porch and fell, injuring his shoulder and foot. Mike brought this lawsuit alleging that his son negligently maintained his yard, causing his injury. The district court ruled in favor of Defendants. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by barring certain standard of care testimony; and (2) did not abuse its discretion when it admitted evidence of Mike's alcohol consumption. View "Roberts v. Roberts" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's most recent motion to correct an illegal sentence on the ground that he was entitled to credit against both of his consecutive sentences, holding that the district court did not err.After the district court denied Defendant's first two motions to correct an illegal sentence pursuant to Wyo. R. Crim. P. 35(a), Defendant filed a third motion pursuant to Rule 35(a) asking the district court to award him credit for 426 days of presentence confinement. The district court denied the request, concluding that the doctrine of res judicata had preclusive effect in this case. The Supreme Court affirmed, holding (1) while Defendant's appeal could be barred by res judicata this Court exercises its discretion to consider the merits of the appeal; and (2) Defendant was entitled to receive 426 days of presentence confinement, and because Defendant received that credit against his total term of imprisonment, his sentence was legal. View "Cruzen v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for second-degree sexual abuse of a minor, holding that there was sufficient evidence to support the conviction.After a jury trial, Defendant was convicted of second-degree sexual abuse of a minor under Wyo. Stat. Ann. 6-2-315(a)(ii) and third-degree sexual abuse of a minor under Wyo. Stat. Ann. 6-2-316(a)(iv). On appeal, Defendant challenged the sufficiency of the evidence supporting only his conviction for second-degree sexual abuse of a minor, arguing there was insufficient evidence of intent to support the conviction. The Supreme Court affirmed, holding that, under the facts and circumstances of this case, the evidence was sufficient to support the conviction for second-degree sexual abuse of a minor. View "Morris v. State" on Justia Law

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