Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony property destruction, sentencing him to a term of imprisonment and probation, and ordering restitution in favor of the victim, holding that there was no error in the restitution order.Defendant pled guilty to felony property destruction. The district court sentenced Defendant to three to five years in prison, suspended in favor of the three years of probation. The district court then ordered restitution in the amount of $7,398. Defendant appealed, challenging the sufficiency of the evidence supporting the restitution award. The Supreme Court affirmed, holding that Defendant waived his right to contest the factual basis for the court's restitution order when he failed timely to object to the victim's damages identified in the presentence investigation report. View "Corr v. State" on Justia Law

The Supreme Court affirmed the judgment of the juvenile court placing MBP, a juvenile, on supervised probation for three to six months after adjudicating him delinquent for fighting in public, holding that the juvenile court did not err in either its adjudication or order of disposition.As part of the disposition, the juvenile court placed MBP on supervised probation for three to six months. MBP appealed, arguing that the evidence was insufficient establish to support the adjudication and that the sentence imposed was contrary to law. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the requisite intent and established an implicit agreement to fight; and (2) MBP failed to establish that the juvenile court's imposition of a three-to-six-month probationary term constituted plain error. View "MBP v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Appellant's declaratory judgment action against Wyoming Governor Mark Gordon and the Wyoming Board of Parole, holding that the district court did not err in concluding that Appellant lacked standing to bring his claims.Appellant, an inmate serving a life sentence and a consecutive five-to-ten-year sentence for crimes to which he pled guilty in 1989, brought this action seeking a declaration that Wyoming's commutation procedures are unconstitutional. The district court dismissed the action, concluding that Appellant lacked standing and that Wyoming's commutation procedures did not violate Appellant's constitutional rights. The Supreme Court affirmed, holding (1) because Appellant did not have an existing or genuine interest in or right to commutation he lacked standing to bring his declaratory judgment action; and (2) commutation decisions involve a political question that is not an appropriate subject for judicial review. View "Weldon v. Honorable Mark Gordon" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of Defendant and dismissing Plaintiff's claims for unjust enrichment, constructive trust, and quiet title, holding that the district court did not err in granting summary judgment to Defendant on all three claims.Plaintiff, Defendant's mother, brought this suit seeking to quiet title to a parcel of property that Defendant acquired when he exchanged it for a parcel of property that his parents deeded to him years earlier. The district court granted summary judgment to Defendant on Plaintiff's claims for unjust enrichment, constructive trust, and quiet title. The Supreme Court affirmed, holding that the right to bring a quiet title action belonged to Defendant, not Plaintiff. View "Statzer v. Statzer" on Justia Law

The Supreme Court reversed the judgment of the district court ruling that North Silo Resources, LLC, the mineral lessee in this case, did not have standing to quiet title or to claim breach of its lease and that North Silo's mineral lease encumbered fifty percent of the mineral estate, holding that the district court erred as to both issues.North Silo brought an action seeking a declaratory judgment and to quiet title in certain minerals underlying property located in Laramie County and bringing a breach of lease claim against the mineral owner. The district court concluded (1) North Silo did not have standing to quiet title or to claim breach of its lease; and (2) North Silo's mineral lease encumbered only fifty percent of the mineral estate. The Supreme Court reversed, holding (1) North Silo had standing to quiet title and to assert a claim for breach of lease; and (2) North Silo's lease encumbered 100 percent of the mineral estate. View "North Silo Resources, LLC v. Deselms" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree sexual abuse of a minor and sentence of two consecutive terms of five to seven years in prison, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued, among other things, that the district court abused its discretion at sentencing by excluding argument and testimony that the victim's parents condoned Defendant's sexual abuse of their daughter and financially extorted him after learning of the abuse. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion at sentencing by refusing to hear argument and testimony that the victim's parents condoned the abuse and used the abuse for financial gain; and (2) properly imposed consecutive sentences of imprisonment rather than probation. View "Villafana v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony shoplifting after a jury trial, holding that the district court did not err or abuse its discretion.On appeal, Defendant argued that his right to a speedy trial was violated and that the district court abused its discretion by allowing a juror who inadvertently saw a video about the trial on social media to remain on the jury. The Supreme Court disagreed and affirmed, holding (1) Defendant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48 or the Sixth Amendment; and (2) Defendant waived any claim related to alleged juror impropriety by not objecting before the return of the verdict. View "Vlahos v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of second-degree murder for the shooting death of his significant other, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the district court did not abuse its discretion when it admitted a certain text message as other acts evidence under Wyo. R. Evid. 404(b); (2) the district court did not abuse its discretion when it permitted the State’s forensic pathologist to opine as to the victim’s manner of death; and (3) there were no clearly improper leading questions involving the prosecutor's personal beliefs or reference to facts not in evidence. View "Anderson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of burglary and other offenses, holding that the district court did not err admitting WiFi records showing Defendant's Apple iPhone connected to his workplace's password-protected WiFI network on the night of the burglary giving rise to Defendant's convictions.Defendant was convicted of burglary, theft, and property destruction for breaking into his workplace and stealing approximately $16,000 in cash. On appeal, Defendant argued that the district court erred in ruling that there was sufficient foundation to allow the WiFi records at issue. The Supreme Court affirmed, holding that assuming that the WiFi records were hearsay, the district court did not abuse its discretion in admitting the evidence under the business records exception. View "Blair v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Wyoming State Board of Equalization (Board) affirming the tax assessment set forth by the Wyoming Department of Revenue (DOR) imposing severance and ad valorem property taxes on the waste mine gas (WMG) captured and used by Solvay Chemicals, Inc., holding that there was no error.Solvay used the WMG released from its trona mining operations to help fuel its soda ash processing plant during the years 2012 through 2015. The DOR imposed severance and ad valorem taxes on the WMG during those years. Solvay objected, arguing that the WMG was not taxable under the severance or ad valorem tax statutes. The Supreme Court affirmed, holding that Solvay failed to show the DOA and DOR improperly valued the WMG for production years 2012-2015. View "Solvay Chemicals, Inc. v. Wyoming Dep't of Revenue" on Justia Law