Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the district court determining that the procedures leading to the dismissal of Petitioner from the City of Rawlins Fire Department violated Petitioner's right to due process and ordering her to be reinstated with back pay, holding that the Rawlins Fire Department Civil Service Commission's decision terminating Petitioner's employment was supported by substantial evidence in accordance with law.The Commission concluded that the reason for Petitioner's discharge was "sufficient and established" pursuant to Wyo. Stat. Ann. 15-5-112(b) because Petitioner violated Civil Service Commission Rules 21.3 and 2.7 and ordered Petitioner's employment be terminated. In so concluding, the Commission explicitly rejected Petitioner's argument that she was denied due process. The trial court reversed, finding that Petitioner's due process rights were violated. The Supreme Court reversed, holding (1) Petitioner was afforded due process prior to her discharge by the Commission; and (2) the Commission's decision was supported by substantial evidence and was not arbitrary or capricious. View "City of Rawlins v. Schofield" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the Wyoming Board of Equalization (Board) concluding that WPX Energy Rocky Mountain, LLC was entitled to deduct some of its "reservation fees," holding that the Board erred in interpreting the plain language of Wyo. Stat. Ann. 39-14-203(b)(vi)(C) in its decision.At issue on appeal was whether and to what extent WPX was entitled to deduct "reservation fees" under the "netback" severance tax valuation method, section(vi)(C), for natural gas production years 2013-2015. The Board concluded that WPX was entitled to deduct some of its reservation fees. The Supreme Court reversed in part, holding (1) the statute allows WPX to fully deduct its pipeline reservation fees for months when some but not the full reserve capacity of gas was transported on that pipeline; (2) the statute does not allow WPX to deduct its Bison Pipeline reservation fees for months when it shipped no gas on the pipeline; and (3) the Board's conclusion that WPX cannot deduct any portion of its Bison Pipeline reservation fees it used to recoup pipeline construction costs was contrary to the plain language of the statute and the Bison agreement. View "Wyo. Department of Revenue v. WPX Energy Rocky Mountain, LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion filed under Wyo. R. App. P. 21 for a new trial based on ineffective assistance of counsel, holding that the district court did not err by denying the motion.After a jury trial, Defendant was convicted of aggravated burglary, aggravated assault and battery, and other crimes after repeatedly confronting his estranged wife and her male friend. On appeal, Defendant argued that the trial court erred in denying his motion for a new trial based on ineffective assistance of counsel. Specifically, Defendant alleged that trial counsel failed properly to advise him of his right to plead not guilty by reason of mental illness. The district court denied the motion, concluding that trial counsel's performance was not deficient. The Supreme Court affirmed, holding that Defendant did not meet his burden to show that prejudice resulted from trial counsel's alleged deficient performance. View "Buckingham v. State" on Justia Law

The Supreme Court affirmed the decision of the district court reversing the decision of the Office of Administrative Hearings (OAH) awarding Plaintiff permanent partial disability benefits (PPD) after she injured her back and left hip while working as a registered nurse, holding that the district court did not err.The OAH awarded Plaintiff benefits after finding that she had made a tangible effort to seek suitable employment given her health, education, training, and experience. The district court reversed, finding that Plaintiff did not present sufficient evidence that she actively sought work and did not present expert medical testimony showing she was incapable of working. The Supreme Court affirmed, holding that the OAH decision was not supported by substantial evidence because Plaintiff did not establish by a preponderance of the evidence that there was no suitable work given her health. View "McBride v. State, ex rel. Department of Workforce Services" on Justia Law

The Supreme Court affirmed the judgment of the district court finding that PNS Stores, Inc. d/b/a Big Lots breached a lease with Capital City Properties, LLC and breached the implied covenant of good faith and fair dealing, holding that the district court did not err by finding that Big Lots breached the implied covenant of good faith and fair dealing.Capital City and Big Lots entered into a lease that required Capital City to deliver commercial property to Big Lots by a certain date. Capital City later filed a complaint against Big Lots alleging breach of contract and the implied covenant of good faith and fair dealing. Big Lots counterclaimed for breach of the lease. The district court found in favor of Capital City on both of its claims and awarded damages. The Supreme Court affirmed, holding that there was no error in the proceedings below. View "PNS Stores, Inc. v. Capital City Properties, LLC" on Justia Law

The Supreme Court affirmed the decision of the district court denying Appellant's post-sentence motions to withdraw his no contest pleas in two separate dockets, holding that the district court did not abuse its discretion in denying Appellant's motions to withdraw his no contest pleas.In one docket, Appellant was charged with one count of burglary. In the other docket, Appellant was charged with one count each of attempted murder and aggravated assault. Pursuant to a plea agreement, Appellant entered a plea of no contest to attempted voluntary manslaughter and burglary. After the sentence was imposed, Appellant unsuccessfully filed motions to withdraw substitution of counsel in both dockets, motions requesting to withdraw his pleas of no contest, and motions in arguing ineffective assistance of counsel. The Supreme Court affirmed the denial of Appellant's motions to withdraw his no contest pleas, holding that there was no abuse of discretion. View "Sena v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court finding that the Spence Group lacked standing to bring the underlying derivative action, holding that the district court did not abuse its discretion in ruling that the Spence Group failed to show it did not have an adequate remedy at law.The dispute in this case was between two factions of the former Board of Directors of the Wyoming Trial Lawyers College - the Spence Group and the Sloan Group. The Spence Group brought a derivative action against the Sloan Group and the College alleging that some or all of the Sloan Group directors should be removed from the Board and seeking a declaration that the Spence Group members were the only duly acting members. The district court dismissed the case for lack of standing. The Supreme Court affirmed, holding that the district court properly granted the Sloan Group summary judgment on its claim that the Spence Group lacked standing to bring its derivative action. View "Spence v. Sloan" on Justia Law

The Supreme Court affirmed the judgment of the district court terminating Carol and John Kennedys' guardianships of two children, including MCM, holding that the district court did not err in terminating the Kennedys' guardianship of MCM and granting guardianship to Jessica and Gilbert Padilla pursuant to 3-3-1101(a)(iv).In 2015, a Colorado court removed GAP, MCM, and EJM from the Padillas' custody and placed them in foster care. The Padillas were GAP's biological parents and MCM's and EJM's relatives and former guardians. In 2016, the court granted guardianship of the three children to the Kennedys, Gilbert's sister and husband. In 2020, the Padillas filed a petition in a Wyoming court to terminate the Kennedys' guardianships. The court terminated the Kennedys' guardianship of GAP and MCM and granted guardianship of MCM to the Padillas. The Supreme Court affirmed, holding that the district court did not err when it (1) terminated the Kennedys' guardianship of GAP; and (2) terminated the Kennedys' guardianship of MCM and granted guardianship to the Padillas. View "Kennedy v. Padilla" on Justia Law

The Supreme Court affirmed the order of the district court affirming the judgment of the Board of County Commissioners of Park County approving Trial County Telephone Association, Inc.'s (TCT) application for a special use permit to construct a 150-foot broadband communications tower in Park County, holding that the Board did not arbitrarily or capriciously in approving the application.Specifically, the Supreme Court held (1) the Board had a rational basis to conclude that the proposed was not oversized, and therefore, the Board's approval of TCT's application did not violate Park County development regulations; and (2) the Park County regulations did not require the Board to consider alternative sites for a project before approving a special use permit, and it therefore did not act arbitrarily or capriciously in approving the application without considering alternative locations for the proposed tower. View "Jolovich v. Board of County Commissioners of Park County" on Justia Law

The Supreme Court affirmed the order of the district court adjudicating JP delinquent and the corresponding order of disposition, holding that Defendant did not receive ineffective assistance of counsel when his attorney failed timely to demand a jury trial.The State filed a delinquency petition alleging that seventeen-year-old JP inflicted sexual intrusion on a thirteen-year-old girl. After a hearing, the juvenile court found that JP committed a delinquent act and sentenced him to one year of juvenile probation. On appeal, JP argued that he was prejudiced by his counsel's failure to timely demand a jury trial. The Supreme Court affirmed, holding that JP failed to show the outcome of his case would have been different if it had been tried to a jury. View "JP v. State" on Justia Law