Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court granting summary judgment on Defendant's claim of juror misconduct in his petition for postconviction relief, holding that the district court did not err in granting summary judgment on the issue without proceeding to an evidentiary hearing.Defendant, a doctor, was convicted of two counts of the second-degree sexual assault of two of his patients. The convictions were affirmed on appeal. Defendant later filed a petition for postconviction relief, alleging numerous claims. Prior to an evidentiary hearing, the district court granted the State's motion for summary judgment on the issue of juror misconduct. The Supreme Court affirmed, holding (1) Defendant's juror misconduct claim was not procedurally barred; and (2) the district court did not err in granting summary judgment to the State without holding an evidentiary hearing on the claim of juror misconduct. View "Harnetty v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendants' renewed motion for judgment as a matter of law and request for a new trial in this negligence action, holding that there was no error or abuse of discretion.Plaintiff, the wrongful death representative for William Gray, brought this action against Defendants for the wrongful death of Gray following a motorcycle vehicle collision in a construction work zone, alleging that Defendants disregarded their duty to implement reasonably safe traffic control at an intersection. The district court entered judgment against Defendants and denied their motion for judgment as a matter of law and request for a new trial. The Supreme Court affirmed, holding that there was no error in the proceedings below. View "JTL Group, Inc. v. Gray-Dockham" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Office of Administrative Hearings (OAH) upholding the Wyoming Workers' Compensation Division's denial of Appellant's request for an endless pool to treat his work-related injury, holding that there was no error.Appellant requested that the Division preauthorize the purchase of a small pool with an underwater treadmill known as an endless pool to help him manage his medical condition. The Division denied the request in part, and the OAH upheld the determination. The district court affirmed. The Supreme Court affirmed, holding (1) the OAH had authority to decide this case; and (2) the OAH properly determined that Appellant was collaterally estopped from relitigating his right to an endless pool for treatment because the issue was fully decided in an earlier OAH order denying the claim. View "McCallister v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court affirmed the orders entered by the district court in this divorce case, holding that there was no error in the proceedings below.On appeal, Husband argued that the district court erred by enforcing the parties' Mediated Settlement Agreement (MSA) and incorporating its terms into a decree of divorce, erred when it denied his motion for sanctions for Wife's alleged failure to disclose assets, and erred when it denied his motion to dismiss for forum non conveniens. The Supreme Court affirmed, holding (1) the district court did not err by incorporating the terms for the MSA into a decree of divorce; (2) the district court did not abuse its discretion when it denied the motion for sanctions as moot; and (3) the MSA resolved any outstanding issues relating to forum non conveniens. View "Pellet v. Pellet" on Justia Law

The Supreme Court affirmed Defendant's conviction of six counts of first degree sexual assault, two counts of sexual exploitation of a child, and one count of blackmail, holding that there was no error in the proceedings below.On appeal, Defendant argued that the evidence was insufficient to support his convictions for sexual exploitation of a child and argued that the district court abused its discretion in admitting evidence of his prior conviction. The Supreme Court affirmed, holding (1) there was sufficient evidence to support Defendant's convictions for sexual exploitation of a child; and (2) the district court did not err by admitting evidence of Defendant's prior conviction under Wyo. R. Evid. 404(b). View "Barrett v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant, following a jury trial, of various methamphetamine-related offenses and sentencing him to four to eight years in prison, holding that there was no error or abuse of discretion in the proceedings below.Specifically, the Supreme Court held (1) the district court did not err by failing to recuse herself where she previously represented Defendant when she served as a state public defender because Defendant failed to show via affidavit that the judge was biased or prejudiced against him; and (2) the district court did not abuse its discretion by denying without prejudice Defendant's motion in limine to admit certain evidence under Wyo. R. Evid. 608(b). View "Gilbert v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of felony possession of a deadly weapon with unlawful intent, holding that there was no error in the proceedings below.Defendant pleaded nolo contendre to one count of felony possession of a deadly weapon with unlawful intent. Defendant subsequently filed a motion to withdraw his no contest plea pursuant to Wyo. R. Crim. P. 32(d), which the district court denied. After Defendant was sentenced he filed a motion to withdraw his plea pursuant to Wyo. R. App. P. 21. The district court denied the motion. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant's Rule 21 motion to withdraw his plea on grounds of ineffective assistance of counsel; and (2) the district court correctly exercised its discretion in denying Defendant's Rule 32(d) motion because Defendant did not present a fair and just reason for withdrawal. View "Delgado v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court ruling that pursuant to the doctrine of merger, the parties in this case held certain property as joint tenants with rights of survivorship, holding that the district court reached the correct result.Julie Ann Bell and her longterm romantic partner, Patrick Dominick, owned property together. After Bell died, the executor for her estate brought this action claiming that the parties held the property as tenants in common. Dominick answered, alleging that he and Bell took title as joint tenants with rights of survivorship. The district court granted judgment in favor of Dominick. The Supreme Court affirmed, holding that the district court correctly held that Bell and Dominick held the property as joint tenants with rights of survivorship. View "CIBC National Trust Co. v. Dominick" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court in this complaint against the Trustees of the Beckton Ranch Trust (BRT) seeking declaratory judgment, damages for breach of fiduciary duty, and an accounting, holding that the district court erred in part.In 2018, Waldo Forbes gifted his shares in the BRT to two of his stepsons. The Trustees exercised an option within the trust instrument to reacquire the gifted shares at "fair value." After the beneficiaries purchased their shares Forbes brought this complaint. The district court found that Forbes did not have standing to seek declaratory relief and that the Trustees did not breach their duty of loyalty and had rendered an inadequate accounting. Thereafter, the Trustees filed a new accounting, which the district court found to be sufficient. The Supreme Court reversed in part, holding (1) Forbes lacked standing to seek declaratory judgment; (2) with one exception, the Trustees did not breach their duty of loyalty by using a sealed bidding process to appraise the "fair value" of the shares; (3) one Trustee breached her duty of loyalty through impermissible self-dealing; and (4) the annual accounting contained clear, complete, and accurate information as required under common law. View "Forbes v. Forbes" on Justia Law

The Supreme Court affirmed the judgment of the district court in this dispute about who owned an undeveloped .53-acre parcel in Teton Village and whether it should be sold or conserved, holding that there was no reversible error.Many different parties in this case asserted different ownership theories as to the parcel at issue, depending on which entity they claimed to derive their interest from. The district court had issued several summary judgment orders and related rulings, which the Supreme Court affirmed. At issue in these cross-appeals was whether the receivership order pertaining to a 2006 LLC was an appealable order. The Supreme Court affirmed, holding (1) laches barred Tram Tower Townhouse Association's claim that a 1998 conveyance was unlawful, and therefore, the Association could not challenge the later-issued receivership order; and (2) the district court did not abuse its discretion by failing to order the receiver to maintain the 2006 LLC as a going concern. View "Dvorson v. Weiner" on Justia Law