Justia Wyoming Supreme Court Opinion Summaries

Matthew Justin Olson was convicted by a jury of conspiracy to commit first-degree murder. Olson was incarcerated in the Platte County Detention Center on federal charges and had pending state charges for domestic violence against his ex-wife, SK, who was a key witness. Olson asked his cellmate, Danny Hendershott, to kill SK in exchange for a government stimulus check. Hendershott initially agreed but later reported the plot to law enforcement, leading to an undercover operation by the ATF. Olson was subsequently charged with conspiracy to commit first-degree murder.The District Court of Uinta County allowed the State to introduce evidence under Rule 404(b) of the Wyoming Rules of Evidence, indicating Olson had other serious charges pending. Olson objected, arguing this evidence was prejudicial. The court limited the State to stating Olson had four serious charges pending and SK was an important witness. Olson was found guilty and sentenced to life imprisonment. He appealed, claiming the district court erred in its pretrial ruling on the admissibility of the 404(b) evidence.The Supreme Court of Wyoming reviewed the case and found that the word "serious" was never actually introduced during the trial. The State's evidence was limited to stating Olson had pending charges without categorizing them as serious. The court held that Olson's substantial rights were not affected by the district court's pretrial ruling since the evidence presented at trial was in line with what Olson deemed appropriate. Consequently, any potential error in the pretrial ruling was deemed harmless. The Supreme Court of Wyoming affirmed Olson's conviction. View "Olson v. State" on Justia Law

Appellee filed a complaint against Appellant alleging breach of written agreements for the lease of oil storage tanks. During the bench trial, the district court amended the complaint to include an oral guarantee to pay for the leases, which Appellant was not allowed to rebut. The court found Appellant breached the oral guarantee and awarded damages to Appellee.The District Court of Campbell County initially found in favor of Appellee, determining that Appellant breached the oral guarantee and awarded $114,537.56 in damages. Appellant raised multiple issues on appeal, including the admission of evidence, the application of the statute of frauds, and the effect of a settlement with a co-defendant.The Supreme Court of Wyoming reviewed the case and found that the district court did not abuse its discretion in admitting various exhibits into evidence. The court also held that the statute of frauds defense was waived as it was not raised at trial. Additionally, the court found that the settlement with the co-defendant did not preclude Appellee from pursuing claims against Appellant.However, the Supreme Court of Wyoming determined that the district court abused its discretion by not allowing Appellant to testify regarding the oral guarantee. The court affirmed the district court's rulings on the other issues but reversed and remanded the case for the limited purpose of allowing Appellant to testify about the oral guarantee. The remand is specifically for reconsideration of the personal guarantee and to provide both parties an opportunity to introduce evidence on that issue. View "Sorum v. Sikorski" on Justia Law

Everett Bray was convicted of felony stalking his ex-wife, MS, in violation of Wyoming Statute § 6-2-506(b)(iv) and (e)(iv). After being released from prison for a prior domestic violence offense against MS, Bray went to MS’s residence in June 2022, despite being warned by the sheriff’s department not to trespass. He threatened MS and her mother, leading to his arrest and a no-contact order. In January 2023, Bray returned to MS’s property, violating the protection order, and attempted to take her dog, resulting in another arrest.The District Court of Converse County sentenced Bray to 42-84 months in prison after a jury found him guilty of felony stalking. Bray appealed, arguing that the State presented insufficient evidence to prove he had the specific intent to harass MS.The Wyoming Supreme Court reviewed the case, applying the standard that assumes the State’s evidence is true and gives the State the benefit of every favorable inference. The court found that Bray’s actions, including his threats and repeated visits to MS’s property despite warnings and a protection order, demonstrated a continuity of purpose and intent to harass. The court held that a rational jury could find Bray’s conduct showed specific intent to harass MS, affirming the conviction. View "Bray v. The State of Wyoming" on Justia Law

Joseph Lyle Fredrick was charged with multiple counts of possession of controlled substances and misdemeanor theft in June 2021. He pled guilty to felony possession of marijuana and misdemeanor possession of heroin, leading to the dismissal of other charges. The district court sentenced him to 117 days for the misdemeanor, with credit for time served, and three to five years for the felony, suspended for three years of supervised probation. His probation was transferred to Oregon.In September 2023, the State filed a petition to revoke Fredrick’s probation, alleging he absconded and had no contact with his probation officer after July 2023. He was arrested in Oregon in November 2023, transported to Wyoming in December, and remained in custody. The district court held an initial appearance on December 19 and set an adjudication hearing for December 27. The State moved to allow the probation officer to testify by video, which the court granted. The hearing was continued to January 5, 2024, due to discovery issues and the probation officer’s failure to appear.At the January 5 hearing, the probation officer testified by video, and Fredrick moved to dismiss the revocation petition due to discovery violations. The court denied the motion but continued the hearing to January 19 to resolve the discovery dispute. On January 19, the court denied Fredrick’s motion to dismiss, found certain documents privileged, and concluded there was good cause for the continuances. The court revoked Fredrick’s probation and reinstated his three- to five-year sentence, with credit for time served.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court held that the district court did not abuse its discretion in extending the revocation hearing beyond the 15-day limit, allowing the probation officer to testify by video, and determining that certain probation records were privileged. The court also found that the discovery dispute did not warrant dismissal of the petition. View "Fredrick v. The State of Wyoming" on Justia Law

Marco Cardenas filed a negligence lawsuit against Rajean Fossen following a motor vehicle accident near Hudson, Wyoming. During the trial, Cardenas moved for judgment as a matter of law on Fossen’s liability, which the district court denied, allowing the jury to decide. The jury found Fossen was not negligent. Cardenas then renewed his motion for judgment as a matter of law and filed a motion for a new trial, both of which the district court denied. Cardenas appealed, arguing the district court should have granted his motion for judgment as a matter of law and remanded the case for a new trial on causation and damages.The district court of Fremont County initially granted Cardenas’s motion for summary judgment on Fossen’s affirmative defense of comparative fault but denied summary judgment on Fossen’s liability, citing a genuine issue of material fact. After a four-day jury trial, the jury found Fossen was not negligent. Cardenas’s post-trial motions for judgment as a matter of law and for a new trial were denied by the district court.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court held that Fossen’s statements during the trial did not constitute an unqualified admission of liability. The evidence presented allowed for more than one reasonable inference, and the jury could reasonably conclude that Fossen was not negligent. The court also found that the district court did not abuse its discretion in denying Cardenas’s motion for a new trial, as there was sufficient evidence to support the jury’s verdict. The Supreme Court affirmed the district court’s rulings, upholding the jury’s finding that Fossen was not negligent. View "Cardenas v. Fossen" on Justia Law

The case involves Wade Bloedow (Husband) and Nicole Maes-Bloedow (Wife), who married in 2017 and filed for divorce in 2022. The district court granted the divorce, divided the marital property, and ordered Husband to pay child support and temporary alimony. Husband appealed, arguing the district court abused its discretion in property distribution, income calculation for child support, and the award of temporary alimony. He also claimed the court failed to credit him for temporary payments made during the divorce proceedings.The District Court of Sweetwater County initially granted Wife temporary custody of the twins and ordered Husband to pay $3,000 per month in child and spousal support, plus the monthly payment on Wife’s vehicle. The court found Husband in contempt for not paying the full amount and allowed him to purge his contempt by selling marital assets and paying Wife from the proceeds. After a bench trial, the court awarded Wife most of the marital assets and assigned Husband most of the debts, citing his lack of credibility and fraudulent behavior in concealing and dissipating assets.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court found the district court acted within its discretion in determining the equity in the marital home and awarding Wife $75,000. It also upheld the overall property distribution, noting the district court considered the statutory factors and Husband’s fraudulent actions. The court found no abuse of discretion in the income calculation for child support, as the district court reasonably averaged Husband’s income from 2021 and 2022. The award of temporary alimony was also upheld, as the district court found Wife had a need for support and Husband had the ability to pay. Finally, the court affirmed the district court’s decision on past due support payments, finding the district court properly credited Husband for payments made during the divorce proceedings. View "Bloedow v. Maes-Bloedow" on Justia Law

In this case, Four Thirteen, LLC filed a complaint against three corporate entities and several individuals, including Joshua Wearmouth, Larry Stephens, Edmond X. Moriniere, Ronald G. Meyers, and David C. Norton. The complaint alleged that Wearmouth and Stephens solicited funds from Four Thirteen for a business venture involving Brazilian carbon credits, which turned out to be fraudulent. Four Thirteen claimed that the corporate entities did not own the carbon credits and that Wearmouth and Stephens made numerous misrepresentations. The complaint included claims of breach of contract, fraud, negligent misrepresentation, and other related allegations.The District Court of Laramie County reviewed the case and rejected the affidavits of non-involvement filed by Moriniere, Meyers, and Norton, who sought dismissal from the suit. The court found that there were factual issues regarding their involvement in the alleged fraud. Additionally, the district court imposed discovery sanctions and entered a default judgment against all defendants, including the individual appellants, for failing to comply with discovery orders.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision regarding the affidavits of non-involvement. The Supreme Court determined that the district court correctly found that there were factual disputes about the involvement of Moriniere, Meyers, and Norton, which precluded their dismissal from the case.However, the Supreme Court reversed the district court's decision to impose discovery sanctions against the individual appellants. The Supreme Court found that the appellants were not given proper notice that they were subject to sanctions under Wyoming Rule of Civil Procedure 37(b) and that there was no evidence they violated any prior discovery order. The court held that the sanctions against the individual appellants were not justified and remanded the case for further proceedings consistent with its opinion. View "Stephensv. Four Thirteen, LLC" on Justia Law

Stage Stop, Inc. purchased a lot in the Rafter J Ranch Subdivision in Teton County, Wyoming, intending to convert an existing building into workforce housing apartments. The Rafter J Ranch Homeowner’s Association (HOA) sought a declaratory judgment that this proposed use violated the subdivision’s covenants, conditions, and restrictions (CCRs). The district court granted summary judgment in favor of Stage Stop, determining that the proposed use was permitted under the CCRs, and the HOA appealed.The district court found that the CCRs allowed for "any commercial purpose" on Lot 333, which included Stage Stop’s proposed use of the building for workforce housing. The court reasoned that renting out apartments as a for-profit enterprise fell within the definition of a commercial purpose. The HOA argued that the CCRs, when read as a whole, intended to maintain the residential character of the subdivision and that the proposed use was inconsistent with this intent. The HOA also contended that Stage Stop should be judicially estopped from asserting that the CCRs permitted the proposed use because Stage Stop had previously indicated it would seek to amend the CCRs.The Wyoming Supreme Court affirmed the district court’s decision. The court held that the term "commercial" in the CCRs was clear and unambiguous and included the proposed use of the property for workforce housing. The court rejected the HOA’s argument that the CCRs, when read in their entirety, prohibited the proposed use, noting that the CCRs expressly allowed for "any commercial purpose" on Lot 333. The court also found that the Master Plan referenced by the HOA was inadmissible extrinsic evidence and that the argument related to the "local commercial" designation in the Plat Notes was not properly raised before the district court. Finally, the court concluded that judicial estoppel did not apply because the statements made by Stage Stop in a letter to the County Commissioners were not judicial declarations and did not involve the same issues or parties as the current case. View "Rafter J Ranch Homeowner's Association v. Stage Stop, Inc." on Justia Law

Casey and Janae Ruppert entered into a contract to purchase ranch property from Judith Merrill. Before closing, Merrill indicated she would not proceed with the sale. The Rupperts filed a complaint seeking specific performance and damages. The district court found Merrill breached the contract and denied her affirmative defenses. It awarded the Rupperts damages and attorneys’ fees but declined to order specific performance. The Rupperts appealed the denial of specific performance, and Merrill cross-appealed the attorneys’ fees award.The District Court of Laramie County found Merrill breached the contract but declined to order specific performance, citing Merrill’s personal circumstances and misunderstandings about the contract. It awarded the Rupperts $22,342 in damages and granted their motion for attorneys’ fees without explanation, awarding $55,258.50 in fees and $3,082.60 in costs.The Wyoming Supreme Court reviewed the case and found the district court abused its discretion by denying specific performance. The court noted the district court’s findings contradicted its decision, as it found the contract valid, the price reasonable, and no undue influence or unconscionability. The Supreme Court held that specific performance was the appropriate remedy given the circumstances and the equities involved.Regarding attorneys’ fees, the Supreme Court agreed with both parties that the district court erred by awarding fees without explanation. The Supreme Court independently assessed the reasonableness of the fees, concluding that the rates charged were excessive for the local market. It reduced the hourly rate to $250, resulting in a total fee award of $28,425.00, plus the previously awarded costs of $3,082.60.The Wyoming Supreme Court reversed the district court’s orders denying specific performance and awarding attorneys’ fees, remanding the case for entry of an order consistent with its opinion. View "Merrill v. Ruppert" on Justia Law

Donald Floyd Detimore was convicted of sexually abusing his step-granddaughter, MD, when she was between seven and nine years old. MD disclosed the abuse during a medical checkup at age sixteen, leading to an investigation where she detailed the abuse, including inappropriate touching and forced sexual acts. Detimore denied the allegations but admitted to behaviors that could be seen as inappropriate.The District Court of Fremont County denied Detimore's pretrial motion to introduce evidence under the rape shield statute, which he argued was crucial to his defense. This evidence pertained to an "embarrassing and shameful situation" involving MD, which Detimore claimed would show a motive for MD to fabricate the allegations. The court found the evidence's probative value did not substantially outweigh its prejudicial effect and thus excluded it. Detimore was subsequently found guilty by a jury and sentenced to 40-50 years in prison.The Wyoming Supreme Court reviewed the case and upheld the lower court's decision. The court found that the district court did not abuse its discretion in excluding the evidence under the rape shield statute, as Detimore failed to show a direct link between the "embarrassing and shameful situation" and MD's motive to lie. The court also determined that Detimore's constitutional rights to confront witnesses and present a complete defense were not violated, as he was able to challenge MD's credibility through other means during the trial. The Supreme Court affirmed the conviction and sentence. View "Detimore v. State" on Justia Law