Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of one count of sexual assault in the third degree, holding that the district court did not err when it allowed the State to amend the felony information before submitting the case to the jury.The State charged Defendant by felony information with three identical counts of sexual assault in the third degree. Before trial, the district court asked the State to differentiate the charges, but the court did not act immediately on the request. After the State's presentation of evidence Defendant moved for a judgment of acquittal on the ground that the felony information did not differentiate between the counts. The district court denied the motion and granted the State's motion to amend the felony information. After Defendant was convicted he appealed. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it allowed the State to amend the felony information during trial; and (2) Defendant's substantial rights were not prejudiced by the amendment. View "Roberts v. State" on Justia Law

The Supreme Court reversed the judgment of the district court sentencing Defendant to the maximum term of fifteen to twenty years for aggravated vehicular homicide and a concurrent six months for driving under the influence, holding that the district court plainly erred when it considered Defendant's silence and community expectations in sentencing her.On appeal, Defendant argued that her constitutional right to a fair sentence was violated when the district court "emphasized, and likely punished, her decision to exercise her constitutional rights at the time of her arrest" and when the court expressed that "the severity of the sentence depended upon the county in which it presided over her." The Supreme Court agreed and remanded the case for a new sentencing hearing, holding that the district court erroneously incorporated constitutionally-prohibited factors into its sentencing decision and that the application of those constitutionally-prohibited factors in sentencing undermined the fairness and integrity of the judicial proceedings. View "Jewkes v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court modifying Father's child support order and ordering Father to pay $4,596.71 in child support arrears, holding that the district court did not abuse its discretion.In 2012, the district court entered an order establishing custody and support for Father's and Mother's children. The Department of Family Services, Child Support Enforcement Division later filed a petition to modify Father's child support order. Father answered, requesting that he be relieved of his child support arrears. The district court denied Father's request for relief, modified the child support order, and ordered Father to pay child support arrears. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it denied Father's request for relief from the 2012 child support order. View "Carroll v. State ex rel. Department of Family Services" on Justia Law

The Supreme Court affirmed Defendant's conviction of attempted first-degree arson, entered after a jury trial, holding that the evidence was sufficient to support the conviction and that the district court did not commit plain error by allowing a police officer to testify that gasoline is an accelerant.On appeal, Defendant argued that the State presented insufficient evidence to support his attempted first-degree arson conviction and that a police officer improperly opined as an expert that a liquid he identified as gasoline found in Defendant's home was an accelerant despite not being qualified to testify as an expert under Wyo. R. Evid. 702. The Supreme Court affirmed, holding (1) sufficient evidence supported the conviction; and (2) as to his remaining assignment of error, Defendant failed to satisfy the second prong of plain error review. View "Esquibel v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for misdemeanor stalking and strangulation of a household member, entered upon his guilty plea, holding that Defendant gave a sufficient factual basis to support his guilty plea.At the change of plea hearing when he was asked about the factual basis for the counts, Defendant did not give detailed answers, instead providing "yes" answers to the questions of both counsel and the court. After Defendant's attorney questioned him, the trial court found there was a factual basis for both counts and accepted Defendant's plea. The Supreme Court affirmed, holding that the district court did not violate a clear and unequivocal rule of law when it accepted his guilty plea. View "Beeson v. State" on Justia Law

The Supreme Court affirmed the order of the district court denying Robert Gill's motion to enforce a judgment confirming arbitration awards entered against Elizabeth Lockhart, holding that there was no error in the proceedings below.Siblings Robert Gill and Lockhart were the beneficiaries of a trust that owned land in Teton County. The trust decided to use the land to create a subdivision. This case concerned an arbitration award contained in an order covering the parties' rights and obligations regarding the subdivision. Gill successfully filed a petition asking the district court to confirm two of the arbitration awards. Thereafter, Gill filed his motion to enforce the judgment. The district court denied the motion, finding that Gill failed to prove some of his damages. The Supreme Court affirmed, holding that the district court did not abuse its discretion by not allowing Defendant to present certain evidence either at the evidentiary hearing or after the district court announced its oral ruling. View "Gill v. Lockhart" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony possession of marijuana, entered following Defendant's conditional guilty plea, holding that the initial traffic stop of Defendant in this case comported with the requirements of the Fourth Amendment to the United States Constitution.In denying Defendant's motion to suppress, the trial court concluded that the initial traffic stop was justified as a drug trafficking investigation. Defendant appealed, arguing that the district court erred in concluding the officer had reasonable suspicion to stop Defendant based on the collective knowledge doctrine. The Supreme Court affirmed, holding that the initial stop was legally justified under the Fourth Amendment, and therefore, the district court did not err in denying Defendant's motion to suppress. View "Guandong v. State" on Justia Law

The Supreme Court affirmed the judgment of the Wyoming Workers' Safety and Compensation Division denying coverage for Claimant's thoracic spine treatment, holding that the Medical Commission's decision was supported by the hearing evidence.After the Division denied Claimant's compensation coverage for his thoracic spine treatment Claimant appealed. The Compensation Commission upheld the denial of coverage following a contested pain hearing, and the district court affirmed. The Supreme Court affirmed, holding (1) the record contained substantial evidence to support the Commission's findings that Claimant's thoracic spine injury was unrelated to his work-related accident; and (2) Claimant failed to meet his burden of proving that his thoracic spine evaluation and treatment were compensable under the "rule out" doctrine. View "Hart v. State of Wyoming, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court reversed the order of the district court granting summary judgment in favor of Defendant on her counterclaim for breach of contract in this legal malpractice lawsuit, holding that there was a genuine issue of material fact as to whether the parties entered into a lawfully enforceable settlement agreement.The underlying lawsuit arose after the death of Plaintiff's mother when Defendant failed timely to file an application with the Wyoming Medical Review Panel and a wrongful death lawsuit. Defendant filed a counterclaim for breach of contract, alleging that the parties had entered into a valid agreement to settle the legal malpractice claim for $100,000. The district court granted summary judgment in favor of Defendant, concluding that the settlement agreement was enforceable. The Supreme Court reversed, holding that there was a genuine issue of material fact about whether the parties had a setting of the funds on the issue of who was settling and who would be bound by the settlement, precluding summary judgment. View "Kappes v. Rhodes" on Justia Law

The Supreme Court affirmed the judgment of the probate court denying the motion for an order to show cause filed by Cynthia Soames, the personal representative of her brother's estate, against Dick Gifford, the estate's previous personal representative, holding that the probate court did not err.In her motion, Soames argued that certain items went missing from the estate while Gifford was personal representative and requesting that Gifford account for those items. The probate court denied the motion after a hearing, thus declining to hold Gifford in contempt, finding that Gifford's testimony was credible and that Soames did not meet her burden of proving that Gifford took and failed to return the items. The Supreme Court affirmed, holding that the court did not err when it determined that Gifford's testimony was credible. View "Soares v. Gifford" on Justia Law