Justia Wyoming Supreme Court Opinion Summaries

William Patterson was convicted of sexually abusing his girlfriend’s four-year-old niece. The incident occurred on September 15, 2019, when Patterson was watching the child and her twin sister. The children later reported the abuse to their mother, who contacted the police. The children were interviewed, and one disclosed the abuse. However, the district attorney initially decided not to charge Patterson. Three years later, the children provided more details, leading to charges against Patterson. He was convicted by a jury of second and third-degree sexual abuse of a minor.The District Court of Natrona County sentenced Patterson to 14-20 years in prison for second-degree sexual abuse of a minor, noting that the same act formed the basis for both convictions. Patterson appealed, arguing that the prosecutor improperly commented on his right to remain silent during the trial. The district court had denied Patterson’s motion for a mistrial, concluding that the prosecutor’s statement was not an improper comment on his right to remain silent and that any potential prejudice was mitigated by the court’s curative actions.The Supreme Court of Wyoming reviewed the case and determined that the prosecutor’s statement during opening arguments, which mentioned Patterson’s refusal to speak with law enforcement, was an impermissible comment on his constitutional right to remain silent. The court reaffirmed that such comments are prejudicial per se under the Wyoming Constitution and require reversal of the conviction. The court overruled previous case law that allowed for a distinction between a “comment” and a “reference” to silence, clarifying that any improper comment on the right to silence is prejudicial per se. Consequently, the Supreme Court of Wyoming reversed Patterson’s conviction and remanded the case for a new trial. View "Patterson v. State" on Justia Law

A mother (TH) appeals a juvenile court's decision to change the permanency plan for her minor child (LH) from reunification to adoption. LH was taken into state custody shortly after birth due to both mother and child testing positive for opiates. The mother has another child, RH, who remained in her custody. The mother argues that the juvenile court did not consider LH's relationship with RH and that it abused its discretion by changing the plan to adoption despite her maintaining sobriety for six months.The District Court of Park County initially placed LH in the custody of the Department of Family Services (Department) and ordered the mother to abstain from controlled substances and undergo drug testing. Despite entering inpatient treatment and attending counseling, the mother continued to test positive for illegal substances, leading to suspended visitations with LH. The Department recommended changing the permanency plan to adoption after the mother failed to maintain sobriety and secure stable housing and employment.The Wyoming Supreme Court reviewed the case and found that the juvenile court did not abuse its discretion. The court noted that the juvenile court had ample evidence of LH's relationship with RH and the potential for sibling separation. The juvenile court's decision to change the permanency plan to adoption was based on the mother's failure to make sufficient progress on her case plan goals, particularly her sobriety and obtaining a stable living environment, within the statutory timeframe. The court emphasized that children have a right to stability and permanency, which outweighed the mother's progress in the months leading up to the permanency hearing.The Wyoming Supreme Court affirmed the juvenile court's decision to change the permanency plan from reunification to adoption, allowing the Department to cease reunification efforts. View "In re L.H. v. State" on Justia Law

In 2021, Contango Resources, LLC purchased oil and gas production and processing facilities in Fremont and Sweetwater Counties, Wyoming. In 2022, the Fremont County Assessor assessed the taxable value of the property located in Fremont County. Contango appealed the assessment to the Fremont County Board of Equalization, arguing that the County Assessor and her expert consultant failed to properly use the purchase price of the property in their valuations and used improper trending and depreciation factors. The County Board upheld the valuation.The State Board of Equalization and the district court both affirmed the County Board's decision. Contango then appealed to the Wyoming Supreme Court. The main issues on appeal were whether the County Board’s decision to uphold the County Assessor’s rejection of the property’s purchase price as a starting point for valuation was supported by substantial evidence and in accordance with law, and whether the County Board’s decision to uphold the County Assessor’s application of trending and depreciation factors in the valuation was in accordance with law.The Wyoming Supreme Court affirmed the lower court's decision. The Court held that the County Assessor was justified in rejecting the purchase price as a starting point for valuation due to the lack of detailed information and the complexity of the Purchase and Sale Agreement (PSA). The Court also found that the Assessor’s use of trending and depreciation factors outside those recommended by the Department of Revenue was permissible under the Department’s rules, as long as the sources were credible. The Court concluded that the County Board’s rulings were supported by substantial evidence and in accordance with law. View "Contango Resources, LLC v. Fremont County" on Justia Law

Kattie Boline sustained injuries from a car accident and sued JKC Trucking and driver Jerzy Syrzyna for negligence. During her jury trial, Boline violated a stipulated order in limine by mentioning insurance, which led the district court to declare a mistrial. The court found her violation intentional and sanctioned her by ordering her to pay $62,074.95 in defense attorneys’ fees and costs. The court also ruled that no new jury trial would be held until the sanction was paid. When Boline failed to pay, the district court dismissed her case with prejudice and entered judgment against her for the sanction amount.The district court of Sweetwater County initially handled the case, where Boline filed her complaint in 2018. The case experienced several delays before being set for trial in August 2022. During the trial, Boline’s mention of insurance, despite a pretrial order prohibiting such testimony, led to the mistrial. The district court then sanctioned her and conditioned a new trial on the payment of the sanction. Boline’s inability to pay the sanction led to the dismissal of her case with prejudice.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The Supreme Court held that the district court did not abuse its discretion in sanctioning Boline and dismissing her case with prejudice. The court found that the district court properly considered Boline’s mental health condition, financial situation, and the reasonableness of the attorneys’ fees and costs. The Supreme Court also held that the district court did not violate Boline’s right to open access to the courts under the Wyoming Constitution, as the sanction and subsequent dismissal were appropriate responses to her intentional violation of the court’s order. View "Boline v. JKC Trucking" on Justia Law

George Kevin Dickerson was convicted by a jury of second-degree murder and attempted second-degree murder. The case arose from an incident on January 8, 2023, when Dickerson called 911 and confessed to killing his mother-in-law, Rose Dennis, and her husband, Andy Martin, with a kitchen knife. Police found Martin dead and Dennis severely injured. Dickerson claimed that an accidental overdose of his antidepressant medication, venlafaxine, caused a violent outburst and a disconnect from reality, leading to his actions.The District Court of Natrona County oversaw the initial trial. Dickerson entered pleas of not guilty and not guilty by reason of mental illness or deficiency (NGMI). The court ordered a mental examination, which concluded that Dickerson did not have a mental illness or deficiency that would absolve him of criminal responsibility. The court also admitted evidence of a prior statement by Dickerson about provoking Martin to facilitate moving Dennis to an assisted living facility, following a Gleason hearing.The Supreme Court of Wyoming reviewed the case. Dickerson appealed, arguing that the district court erred in its jury instructions regarding his NGMI plea and the inference of malice from the use of a deadly weapon. He also contended that the court abused its discretion in admitting his prior statement about Martin. The Supreme Court found no plain error in the jury instructions, noting that the NGMI instruction allowed the jury to consider whether Dickerson’s overdose was involuntary. The court also upheld the instruction on inferring malice from the use of a deadly weapon, citing precedent. Additionally, the court found no abuse of discretion in admitting the prior statement, as the district court had carefully considered its relevance and potential for unfair prejudice.The Supreme Court of Wyoming affirmed Dickerson’s convictions. View "Dickerson v. State" on Justia Law

Vernon Black sued Kari Winfield for breach of contract, while Winfield and Samuel Robinson counterclaimed for unjust enrichment against Black. Winfield and Robinson performed various tasks for Black, including constructing fences, branding cattle, and boarding livestock, without receiving compensation or credit towards Winfield's debt to Black. Black had previously secured a judgment against Winfield for $25,828.52 for unpaid legal expenses.The District Court of Fremont County held a bench trial and found that none of the parties established their claims. Specifically, the court found that Winfield and Robinson did not prove their unjust enrichment claims because they failed to show they reasonably notified Black of their expectation of payment and did not prove damages. Winfield and Robinson appealed the decision.The Supreme Court of Wyoming reviewed the case and found that the district court erred in its findings. The Supreme Court determined that the circumstances reasonably notified Black that Winfield and Robinson expected to be compensated for their work. The court noted that Black had a history of paying Winfield for her work, and both Winfield and Robinson directly addressed their expectation of payment with Black on several occasions. Additionally, the nature and quantity of the work performed by Winfield and Robinson indicated that they expected compensation.The Supreme Court also found that Winfield and Robinson proved damages for their day labor, hot shot fees, and boarding and feeding Black's livestock, totaling $22,793.60. The court reversed the district court's decision and remanded the case for entry of judgment in favor of Winfield and Robinson. View "Robinson v. Black" on Justia Law

The case involves a dispute between homeowners in the Dairy Subdivision in Teton County, Wyoming. The appellants, Robert, Linda, and Anthony Schroth, along with Jackson Hole Winery, LLC, were enjoined by the district court from conducting certain commercial activities on their property, which the appellees, Robert and Viesia Kirk, claimed violated the subdivision's covenants. The covenants restrict the use of properties to single-family residential purposes and prohibit commercial activities, although they allow for certain home occupations and agricultural activities.The district court found that the activities of Jackson Hole Winery, which included wine production, sales, and hosting public tastings, were commercial and violated the covenants. The court also found that the appellants' claims of laches, arguing that the Kirks delayed unreasonably in enforcing their rights, were unfounded. The court issued a permanent injunction limiting the winery's activities to those initially approved by the subdivision's design committee in 2010.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision. The Supreme Court agreed that the winery's expanded activities were commercial and violated the covenants. The court also upheld the district court's finding that the Kirks did not delay unreasonably in enforcing their rights, noting that the Kirks only became aware of the full extent of the winery's activities in 2020 and filed suit in 2022. The court found no abuse of discretion in the district court's decision to grant the injunction, as the equities weighed in favor of enforcing the covenants to preserve the residential character of the subdivision. View "Schroth v. Kirk" on Justia Law

Glenn Tyrone Green entered Joel Ingwerson’s residence without invitation and threw liquid bleach in his face, accusing him of being with his wife. Mr. Green also struck Mr. Ingwerson with a BB gun and threatened him. Mr. Ingwerson experienced severe pain, burning sensations, and chemical irritation, leading him to seek medical attention. Mr. Green was charged with one count of unlawful contact and two counts of aggravated assault and battery with a deadly weapon, one related to the bleach and one to the BB gun. The State later dismissed the BB gun charge and amended the Information to include misdemeanor simple battery.Mr. Green pled guilty to aggravated assault and battery with a deadly weapon (bleach) under a plea agreement, which included a six-year sentencing cap. The district court accepted his plea after confirming a factual basis for the charge. Mr. Green later violated the plea agreement by not cooperating with the preparation of his Presentence Investigation Report (PSI), leading to his arrest and the State invoking the "cold plea" provision. The district court sentenced him to six to eight years in prison.The Wyoming Supreme Court reviewed the case, focusing on whether the district court committed plain error by accepting Mr. Green’s guilty plea without a sufficient factual basis that bleach is a deadly weapon. The court concluded that the district court did not err, as there was a sufficient factual basis to determine that bleach, in the manner used by Mr. Green, was reasonably capable of producing serious bodily injury. The court affirmed the district court’s decision, holding that the bleach constituted a deadly weapon under the circumstances of the case. View "Green v. State" on Justia Law

Cameron Curtis Hagen was a passenger in a vehicle stopped for a cracked windshield in Casper, Wyoming. During a search prompted by a canine alert, officers found controlled substances and a pistol. Hagen was charged with misdemeanor possession of marijuana, misdemeanor possession of methamphetamine, and being a felon in possession of a firearm. He initially pled not guilty but later entered no contest pleas to the drug and firearm charges as part of a plea agreement, with the State recommending concurrent sentences.The District Court of Converse County accepted Hagen's no contest pleas and ordered a Presentence Investigation Report (PSI). At sentencing, Hagen objected to details in the PSI's criminal history section, arguing they were improperly sourced from prior PSIs and police reports, contrary to the Wyoming Criminal History Record Act. The district court took his objections under advisement but did not strike the contested details, stating it would not consider them in determining his sentence. Hagen was sentenced to concurrent terms of six months and one to three years, consistent with the plea agreement.The Wyoming Supreme Court reviewed the case, focusing on whether the district court abused its discretion by not excising the contested details from the PSI. The court found that the Criminal Record Act did not prohibit the inclusion of information from prior PSIs or police reports in a PSI. The court also noted that Hagen did not dispute the accuracy of the information, only its source. The court held that the district court did not abuse its discretion, as it explicitly stated it would not consider the contested information in sentencing. The Wyoming Supreme Court affirmed the district court's decision. View "Hagen v. The State of Wyoming" on Justia Law

A mother and father, who married in December 2021 and separated a year later, have two children (twins). The father also has three children from a previous marriage. After their separation, the mother filed for divorce, and the case went to trial to resolve issues of custody, child support, and property division. The district court granted the divorce, determined custody, ordered the father to pay child support, and divided the property.The district court awarded the parents alternating-week custody of the twins, differing from the holiday schedule for the father's children from his previous marriage. The court also granted the mother final decision-making authority regarding the twins. The father was ordered to pay child support based on the mother's income, which the court calculated using her tax returns and other financial documents. The court also divided the equity in the marital home, using an appraised value from October 2023 and the mortgage obligation from December 2022.The father appealed to the Supreme Court of Wyoming, contesting the holiday visitation schedule, the mother's final decision-making authority, the calculation of the mother's income for child support, and the division of the home equity. The Supreme Court of Wyoming reviewed the district court's decisions for abuse of discretion.The Supreme Court of Wyoming affirmed the district court's decisions. It found that the holiday visitation schedule, while different from the father's schedule with his other children, was not an abuse of discretion. The court also upheld the decision to grant the mother final decision-making authority, noting that the district court adequately explained its reasoning. The calculation of the mother's income for child support was supported by sufficient evidence, and the division of the home equity was reasonable given the evidence presented. The Supreme Court concluded that the district court's decisions were within the bounds of reason and did not constitute an abuse of discretion. View "Amadio v. Amadio" on Justia Law