Justia Wyoming Supreme Court Opinion Summaries

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

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