Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court dismissing this complaint alleging negligence for failure to state a claim, holding that there was no error.Neva Larue Moses negligently collided with another vehicle while driving a vehicle owned and insured by Moses Inc., killing her and the other driver. Moses Inc.'s insurer settled the ensuing negligence claim and then canceled Moses Inc.'s policy. Moses Inc. brought this claim against the Estate of Neva Larue Moses and the Neva Larue Moses Living Trust, arguing that the defendants were liable for its increased insurance costs from another insurer. The district court dismissed the complaint for failure to state a claim. The Supreme Court affirmed, holding that a person who borrows another person's vehicle does not owe the vehicle owner a duty to protect it from increased insurance costs. View "Moses Inc. v. Moses" on Justia Law

The Supreme Court affirmed the judgment of the district court modifying an arbitration award compensating Appellant, a rancher, for calf damage he sustained during the 2018 grazing season as a result of grizzly bear predation, holding that the district court did not err in modifying the award.Appellant reported the number of his calves dead from grizzly bear predation to the Wyoming Game and Fish Department and submitted a claim requesting that the Department compensate him $349,730. The Department rejected the damage claim and agreed to compensate Appellant $61,203. After the Commission affirmed Appellant requested arbitration. The arbitrators awarded Appellant $266,685 for his calf damage. The Department filed a motion to modify the arbitration award. The district court granted the motion and modified the award to reflect the amount of $61,203. The Supreme Court affirmed, holding that the arbitrators made an award on a matter not submitted to them and thus did not follow the law. View "Longwell v. Wyoming Game & Fish Department" on Justia Law

The Supreme Court affirmed the order of the Wyoming Public Service Commission (PSC) administering the Wyoming Universal Service Fund (WUSF) for the 2020-2021 fiscal year, holding that the PSC's order was lawful.It issue was the interplay between the Federal Universal Service Fund (FUSF) and the WUSF. The PSC's order adopted a methodology for calculating WSFU disbursements that treated a portion of the 2019 support each Wyoming telecommunications company received from the federal Alternative Connect America Cost Model programs as contributions from the FUSF. Union Telephone Company filed a petition for review, asserting that the order rejected existing law and materially prejudiced Union. The Supreme Court affirmed, holding (1) collateral estoppel did not bar the PSC from adopting a WUSF calculation methodology that considered the A-CAM funds to be FUSF contributions; (2) the PSC's order was lawful; and (3) Union's remaining claims of error were unavailing. View "Union Telephone Co. v. Wyoming Public Service Commission" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of possession of marijuana, holding that the traffic stop in this case was unreasonable under the totality of the circumstances.Defendant was the passenger in a vehicle that was stopped for following a semi-truck too closely. The officer requested a drug-detection canine to be dispatched to the location and subsequently found approximately forty-two pounds of marijuana. Defendant was subsequently charged with two drug-related counts. Defendant moved to suppress the evidence, arguing that the initial traffic stop was unreasonable. The district court denied the motion to suppress, and Defendant entered a guilty plea to count two. The Supreme Court reversed, holding (1) the traffic violation for following too closely was not objectively justified and was unreasonable at its inception; and (2) therefore, the district court erred by denying Defendant's motion to suppress. View "Levenson v. State" on Justia Law

The Supreme Court reversed in part and affirmed in part the decision of the district court granting summary judgment for Meritain Health, Inc., and dismissing David Peterson's claims against Meritain, holding that there were genuine issues of material fact as to some of Peterson's claims.Peterson, an insured under a hospital's health benefit plan, brought this action against the hospital and Meritain Health, Inc., the third-party administrator of the plan, alleging several claims arising from the denial of his claims for health insurance coverage. The district court granted Meritain's motion for summary judgment. The Supreme Court reversed in part and remanded the case, holding that there were genuine issues of material fact regarding Peteron's breach of contract claim, his third-party beneficiary claim, and his claim for breach of the covenant of good faith and fair dealing. View "Peterson v. Meritain Health, Inc." on Justia Law

The Supreme Court reversed the judgment of the district court denying Plaintiff's motion to peremptorily disqualify the judge assigned to her case, holding that the district court erred by denying Plaintiff's motion.Plaintiff brought this action against her coworker and their employer, alleging claims of battery and negligence against her coworker and that the employer failed properly to supervise and control the coworker. The judge assigned to Plaintiff's case subsequently recused himself and assigned another judge to the case. Four days later, Plaintiff filed her motion to peremptorily disqualify the second judge. The district court denied the motion as untimely. The Supreme Court reversed, holding that the motion was timely. View "Berens v. Mumme" on Justia Law

The Supreme Court affirmed Defendant's conviction of possession of marijuana, aggravated fleeing or attempting to elude, reckless endangering, and interference with a peace officer, holding that the district court did not err in denying Defendant's motion to suppress.Defendant pleaded guilty to the offenses, conditioned on his right to appeal the denial of his motion to suppress the fruits of a traffic stop on the ground that the stop violated the Fourth Amendment. On appeal, the parties disputed whether Defendant waived his constitutional claim by filing an untimely motion to suppress. The Supreme Court affirmed, holding (1) Defendant did not waive his Fourth Amendment claim; and (2) the district court did not err in denying Defendant's motion to suppress. View "Barney v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of three counts of delivery of a controlled substance, holding that the exclusion of "distilled spirits, wine, malt beverages, or tobacco" from the Wyoming Controlled Substances Act, Wyo. Stat. Ann. 35-7-1031(a)(ii), did not violate Defendant's constitutional equal protection rights.In his motion to dismiss, Defendant argued that the Act violated his rights to equal protection and substantive due process under the United States and Wyoming Constitutions by operating in an unequal and disparate manner because the Act excludes from its application tobacco and alcohol. The district court denied the motion to dismiss. The Supreme Court affirmed, holding that the regulation of substances contained in the Act was reasonably related to the State's legitimate interests and did not violate Defendant's constitutional right to equal protection. View "Hardison v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of possession of methamphetamine, possession of marijuana, and interference with a peace officer, holding that there was sufficient evidence to support Defendant's conviction for marijuana possession.During trial, the prosecution presented testimony that the green leafy substance found in Defendant's left from pocket was consistent with marijuana, but there was no testimony on the concentration of the substance's THC concentration. On appeal, Defendant argued that, in the absence of proof of the THC concentration, there was insufficient evidence to support his conviction for possession of marijuana. The Supreme Court affirmed, holding (1) under Wyo. Stat. Ann. 35-7-1050(a), Defendant bore the burden of establishing that the substance he possessed had a THC concentration of not more than 0.3 percent; and (2) Defendant failed to meet his burden of proof and made no argument that the evidence was otherwise insufficient to support his conviction. View "Roman v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of Expert Training, LLC after Plaintiff settled with all other defendants in her personal injury lawsuit, holding that the district court did not err.Plaintiff was injured when she fell from the attic of Sunrise Shopping Center to the floor below. Plaintiff sued the Shopping Center's owner, various property management companies, and Expert Training, the staffing company that provided janitorial and maintenance workers to the Shopping Center. Plaintiff settled with all defendants except Expert Training. The district court subsequently entered summary judgment in favor of Expert Training, finding that Expert Training was not engaged in a joint venture and that it owed no duty to Plaintiff. The Supreme Court affirmed, holding that the district court properly granted summary judgment on Plaintiff's joint enterprise and negligence claims. View "Weir v. Expert Training, LLC" on Justia Law