Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the Medical Commission Hearing Panel (Commission) upholding that decision of the Wyoming Workers' Compensation Division denying Claimant's request for permanent total disability (PTD) benefits for a work-related injury that Claimant asserted made him unemployable, holding that the Commission's decision was supported by substantial evidence and was unaffected by any error of law.At issue was Claimant's request for PTD benefits for a work-related back injury Claimant suffered in 2002. The Division denied Claimant's application for PTD benefits, and the Commission upheld the Division's denial of PTD benefits. The Supreme Court affirmed, holding that the Commission correctly determined that Claimant did not meet his burden of proving he was entitled to PTD benefits under the odd lot doctrine. View "Genner v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court affirmed the ruling of the State Board of Equalization affirming the decision of the Wyoming Department of Revenue disallowing a deduction of bagging costs from the taxable value of its bagged soda ash, holding that Solvay Chemicals, Inc. was not entitled to deduct bagging costs from the taxable value of soda ash.In 2013-2015, Solvay deducted its soda ash bagging costs from the taxable value of the bagged soda ash it sold. The Department determined that Wyo. Stat. Ann. 39-14-303(b) did not entitle Solvay to a separate deduction for bagging costs, and the Board and district court affirmed. The Supreme Court affirmed, holding that the Board did not err in determining that the Department's interpretation of section 39-14-303(b)(ii) was not erroneous or contrary to the plain language of Wyo. Stat. Ann. 39-14-303(b)(iv). View "Solvay Chemicals, Inc. v. Wyoming Department of Revenue" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's pre-sentence motion to withdraw his plea of no contest to second-degree murder, holding that the district court did not abuse its discretion.Defendant pleaded no contest to second-degree murder and guilty to first-degree arson, felony theft, and felony burglary. Before sentencing, Defendant filed a pro se motion to withdraw his no-contest plea, alleging that he made the decision to enter the no-contest plea due to ineffective assistance of counsel. After a hearing, the district court denied the motion, ruling that Defendant failed to establish a basis to withdraw his no-contest plea. The Supreme Court affirmed, holding (1) Defendant failed to meet his burden of establishing there was a fair and just reason to allow him to withdraw his no-contest plea; and (2) the district court correctly exercised its discretion in denying Defendant's motion. View "Pettus v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's pro se motion for a sentence reduction filed under Wyo. R. Crim. P. 35(b), holding that the district court did not violate Defendant's right to due process or abuse its discretion in denying Defendant's motion for sentence reduction.After a jury trial, Defendant was convicted of attempted second-degree murder and sentenced to a term of incarceration of between twenty-five to thirty-five years. Defendant appealed, arguing that the denial of his motion for a sentence reduction was the result of the district judge's personal bias against him. The Supreme Court affirmed, holding (1) Defendant failed to establish bias, and therefore, his due process rights under the Fourteenth Amendment of the United States Constitution were not violated; and (2) the district court did not abuse its discretion in denying Defendant's motion for a sentence reduction. View "Leners v. State" on Justia Law

The Supreme Court affirmed the judgment of the juvenile court ordering the permanency plan for minor siblings BP and CS be changed from reunification to adoption, holding that the juvenile court did not abuse its discretion.The Department of Family Services (DFS) recommended changing the permanency plan for BP and CS to adoption. After a permanency hearing, the juvenile court issued an order changing the permanency plan to adoption and relieving DFS from further reunification efforts, finding that DFS established that it had made reasonable efforts to reunify the family. The Supreme Court affirmed, holding that the juvenile court did not abuse its discretion when it concluded that DFS made reasonable efforts to reunify Mother with CS and BP and changed the permanency plan for reunification to adoption. View "NP v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant, after a jury trial, of second-degree murder and domestic battery, holding that the prosecutors' statements during opening and closing argument did not deprive Defendant of a fair trial.A jury found Defendant guilty of second-degree murder and domestic battery. The district court entered judgment upon the verdict and sentenced him to a term of imprisonment of seventy years to life for the murder. Defendant appealed, arguing that the prosecutors committed misconduct during the State's opening statement and during its closing argument. The Supreme Court affirmed, holding that the challenged statements did not prejudice Defendant. View "Rodriguez v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of voluntary manslaughter, holding that the evidence was sufficient to sustain the conviction and that the district court did not err when it instructed the jury on voluntary manslaughter.Defendant was charged with second-degree murder. The jury acquitted Defendant of the charge and found him guilty of the lesser-included offense of voluntary manslaughter. It also found Defendant guilty of aggravated assault and battery. The Supreme Court affirmed, holding (1) the district court correctly instructed the jury on voluntary manslaughter, and there was the minimal evidentiary support necessary to show Defendant acted in a sudden heat of passion; and (2) the evidence was sufficient to support the jury's verdict. View "Fallon v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated assault and battery with a habitual criminal sentencing enhancement, holding that the district court did not abuse its discretion in admitting the State's recording of certain surveillance footage.At issue on appeal was the district court's admission of the State's cell phone recording of a coffee shop's surveillance footage showing the altercation between Defendant and his victim and whether the government's recording was inadmissible secondary evidence because the State put forth no reasonable effort to obtain the original video before the video surveillance was erased from the system. The Supreme Court affirmed, holding that where the State offered a reasonable explanation for its inability to produce the coffee shop's original surveillance footage and the State did not destroy the original in bad faith, the district court did not abuse its discretion in admitting the State's recording of the footage. View "Baker v. State" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of Security State Bank (SSB) on its claims against Dellos Farms, Inc. and other related individuals and entities (Dellos defendants), holding that the district court did not err in ruling that the Wyoming Consumer Protection Act (WCPA), Wyo. Stat. Ann. 40-12-101 through 114, did not apply to the parties' transactions.In its complaint, SSB alleged that Dellos Farms defaulted on two promissory notes it had given to SSB for commercial agricultural loans and sought to foreclose on the collateral securing the notes. The Dellos defendants filed counterclaims alleging that SSB had engaged in improper lending practices under the WCPA. The district court granted summary judgment for SSB on its claims and on the Dellos defendants' counterclaims. The Supreme Court affirmed, holding that the plain language of the WCPA does not permit its application to commercial agricultural loans. View "Dellos Farms, Inc. v. Security State Bank" on Justia Law

The Supreme Court affirmed the judgment the district court denying TEP Rocky Mountain LLC's (TEP RM) motion to dismiss this action, granting summary judgment to Record TJ Ranch Limited Partnership (TJ Ranch) on several issues, and ruling that TEP RM had breached the parties' agreements, holding that there was no error.TJ Ranch brought this action seeking payment under a surface use and damage agreement governing oil and gas development and production of ranch lands. TEP RM filed a motion to dismiss for lack of personal jurisdiction, which the district court denied. The court ultimately concluded that TJ Ranch was entitled to payment. The Supreme Court affirmed, holding that the district court (1) correctly exercised personal jurisdiction over TEP RM; (2) did not clearly err in its findings; and (3) did not abuse its discretion in denying TEP RM's motions to stay. View "TEP Rocky Mountain LLC v. Record TJ Ranch Limited Partnership" on Justia Law