Justia Wyoming Supreme Court Opinion Summaries

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

The Supreme Court affirmed in part and reversed in part Defendant's convictions for sexual abuse, holding that the failure of the instructions in this case to provide the specific direction necessary for a unanimous decision on each charge violated the unequivocal requirement of jury unanimity, and the error was prejudicial.After a jury trial, Defendant was found guilty of three counts of third-degree sexual abuse of a minor (Counts I, II, and III) and one count of attempted second-degree sexual abuse of a minor (Count VI). On appeal, Defendant argued that the jury instructions, which contained identical language for the basis of conviction on Counts I through V, were insufficient to direct the jury to a unanimous verdict on each count. The Supreme Court agreed and reversed Defendant's convictions and Counts II and III, holding that the district court's failure to properly instruct the jury violated a clear and unequivocal rule of law that adversely affected Defendant's substantial rights. View "Walker v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court convicting Defendant of second-degree murder after denying his motion to suppress, holding that the district court erred in determining when Defendant's interrogation became custodial, and that error required reversal.Specifically, the Supreme Court held (1) the district court erred in ruling that Defendant was not in custody during his police station interview until he was directed to remain in an interview room; (2) it was not harmless error to admit incriminating statements Defendant made after his interrogation became custodial; and (3) the record supported the district court's conclusion that Defendant's confession was voluntary. View "Mills v. State" on Justia Law

The Supreme Court affirmed the order of the district court relinquishing jurisdiction over a child custody dispute to Texas pursuant to Wyo. Stat. 20-5-306, holding that the district court did not abuse its discretion when it found that Wyoming was an inconvenient forum and relinquished jurisdiction.Less than a week after Child's birth, Mother filed a petition to establish paternity, custody, and child support. Thereafter, Mother moved to Texas. The district court then entered an order establishing Father's paternity of Child and awarding Mother primary custody. Four years after Mother and Child moved, Mother petitioned a Texas district court to modify visitation and compel Father's participation in parenting facilitation. The Texas court contacted the Wyoming court to discuss the matter of jurisdiction. Ultimately, the Wyoming court determined Wyoming was an inconvenient forum and entered an order relinquishing jurisdiction to Texas. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion when it declined to exercise its exclusive, continuing jurisdiction to modify the child custody order after finding Wyoming was an inconvenient forum; and (2) did not violate Father's due process rights by not requiring the parties to file written pleadings in Wyoming. View "Ruiz v. Fribourg" on Justia Law

The Supreme Court affirmed the decision of the district court in favor of Plaintiff on its action for declaratory judgment and quiet title, concluding that a right-of-way and access easement over a twenty-foot-wide strip of property connecting a public road to land now owned by Plaintiff was appurtenant and continued to benefit Plaintiff, holding that there was no error.Defendant's predecessor granted a right-of-way and access easement over the property at issue, but Defendant denied Plaintiff access across the easement, claiming that the easement was in gross and provided access only to Plaintiff's predecessor in interest. The district court granted summary judgment in favor of Plaintiff. The Supreme Court affirmed, holding that the evidence was insufficient to overcome the presumption of appurtenance. View "Upper Wagon Box, LLC v. Box Hanging Three Ranch Ltd. Partnership" on Justia Law