Justia Wyoming Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the district court ruling that Jill and Shane Ailport (together, Grandparents), the grandparents of five children (collectively, Children), did not prove their right to visitation under the grandparent visitation statute, Wyo. Stat. Ann. 20-7-101, holding that Grandparents did not meet their burden of establishing that visitation was in the best interests of the children.Grandparents filed a petition against parents of Children (collectively, Parents) under Wyo. Stat. Ann. 20-7-101 to establish visitation rights with Children. Applying an enhanced best interest analysis, the district court concluded that Grandparents had not met their burden of proving by clear and convincing evidence that they were entitled to visitation over Parents' objections. View "Ailport v. Ailport" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Appellants' petition for review of a decision of the Board of County Commissioners, Lincoln County under Wyo. R. App. P. 12 and Wyo. Stat. Ann. 16-3-114, holding that the district court abused its discretion by sanctioning Appellants with dismissal of their petition for review.The district court dismissed Appellants' petition, determining that Wyo. R. App. P. 2.06 required a transcript to be filed within sixty days of the filing of the petition for review of agency action and that no transcript was filed. The Supreme Court reversed, holding (1) the district court misstated and misapplied Rule 2.06; (2) the Board failed to transmit the record as required by Rule 12.07; and (3) because the Board, not Appellants, had the responsibility to transmit the entire record to the district court, the court abused its discretion by dismissing the action. View "Depiero v. Board of County Commissioners, Lincoln County" on Justia Law

The Supreme Court affirmed the decision of the Office of Administrative Hearings (OAH) affirming the denial of Appellant's request for benefits related to her injury, holding that substantial evidence supported the agency's decision.On May 3, 2019, Appellant, a sales associate at Flaming Gorge Harley-Davidson, was moving a motorcycle when her back grabbed and her legs felt weak. On May 6, Appellant was standing in her kitchen and turning slightly to the left when she felt excruciating pain. Appellant filed a claim with the Department of Workforce Services, Workers' Compensation Division for benefits related to her May 6 injury. The Division denied Appellant her requested benefits. The OAH and the district court affirmed. The Supreme Court affirmed, holding (1) the law does not require OAH to reference the "second compensable injury" rule in its decision; and (2) there was substantial evidence to support OAH's conclusion that Appellant failed to prove her May 6 injury was caused by the May 3 injury. View "Boylen v. State, ex rel., Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment to Michael McDill on his request that the district court confirm that his brother, Thomas McDill, was excluded as a beneficiary under their deceased mother's trust and dismissing Thomas's counterclaims, holding that there was no error.Michael, as a trustee of the trust, filed a petition for instructions asking the district court to confirm that Thomas was disinherited from taking under the trust because he violated the trust's no-contest provision. In response, Thomas asserted various counterclaims and requested that Michael be removed as trustee. The district court granted summary judgment in favor of Michael, dismissed Thomas's counterclaims, and denied Thomas's motion to amend. The Supreme Court affirmed, holding that there was no error in the district court's judgment. View "McDill v. McDill" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony child endangerment, holding that the evidence was sufficient to support the conviction.After a bench trial, the district court found Defendant guilty of felony child endangerment. At the close of the State's evidence, Defendant moved for judgment of acquittal, alleging that the State had failed to provide sufficient evidence of the elements necessary to convict her. The district court denied the motion. The Supreme Court affirmed, holding that the State presented sufficient evidence to sustain a conviction for child endangerment, and therefore, the district court did not err in denying Defendant's motion for judgment of acquittal. View "Reyes v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Mother's petition filed on behalf of her minor child, SGN, for a change of surname, holding that the district court did not abuse its discretion by denying the petition.While Father and Mother were married, they had SGN. After they divorced, Mother remarried and took the surname of her husband. Mother then filed a verified petition in the district court to change SGN's surname to Lamb-Newman because Mother would be the primary custodian and wanted SGN to share her surname and that of her half sibling. Father objected. The district court denied the petition, finding that the name change was not in SGN's best interest and that it was detrimental to Father's interests. The Supreme Court affirmed, holding that the district court's decision to deny the name change was not an abuse of discretion. View "Lamb v. Newman" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion for sentence reduction pursuant to Wyo. R. Crim. P. 35(b), holding that the district court properly found that it lacked jurisdiction over Appellant's motion.Appellant entered a guilty plea to tattooing a minor, delivery of methamphetamine to a juvenile, and child endangerment. The district court later revoked Appellant's probation and reinstated his original sentence. At issue was Appellant's motion for a sentence reduction that was filed more than one year after Appellant's probation revocation sentence. The district court denied the motion as untimely. The Supreme Court affirmed, holding that Appellant's request for a reduction of sentence was untimely, and therefore, the district court lacked jurisdiction to consider Appellant's motion for a sentence reduction. View "Sherard v. State" on Justia Law

The Supreme Court affirmed the judgment of the Medical Commission Panel denying Appellant's application for additional benefits and an increase to her impairment rating, holding that the Medical Panel's decision was not arbitrary, capricious, or otherwise not in accordance with the law.In 2014, Appellant suffered a workplace injury. In 2019, Appellant applied for additional benefits, including surgery for carpal tunnel syndrome, and an increase to her impairment rating. The Medical Panel denied both requests, determining (1) Appellant's carpal tunnel syndrome was not related to her workplace injury, and (2) Appellant's claim for an increased impairment rating was unsubstantiated. The Supreme Court affirmed, holding that the Medical Panel's ultimate determinations were supported by substantial evidence and were not arbitrary, capricious, or otherwise not in accordance with law. View "Reichenberg v. State, ex rel., Department of Workforce Services" on Justia Law

The Supreme Court reversed the judgment of the juvenile court denying RH's petition for expungement of his record pursuant to Wyo. Stat. Ann. 14-6-241, holding that the district court erred in interpreting sections 14-6-241(d) and (e).When RH was sixteen years old the State filed a delinquency petition against him. RH agreed to a deferred prosecution and successfully completed the terms of his deferral. Thereafter, the juvenile court dismissed the delinquency petition. RH later petitioned for expungement of his record. The juvenile court denied the petition, concluding that RH was statutorily ineligible to have the record expunged because the petition charged him with a violent felony. The Supreme Court reversed, holding that section 14-6-241 allows expungement of a juvenile record where a delinquency petition was dismissed but the delinquent act charged was a violent felony. View "RH v. State" on Justia Law