Justia Wyoming Supreme Court Opinion Summaries

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

The Supreme Court affirmed in part and reversed in part the decision of the district court granting summary judgment to Family Tree Corporation and JD4, LLC (collectively, Family Tree) and dismissing Skyco Resources, LLP's complaint asserting claims for breach of contract, breach of the covenant of good faith and fair dealing, conversion, and fraud/intentional misrepresentation, holding that the district court erred in part.Skyco entered into an agreement with Family Tree for the purchase of mineral interests owned by Family Tree. Before closing, however, Skyco wrote a letter giving notice of its termination of the agreement and demanding a return of its earnest money. Because Skyco failed to comply with the agreement's termination provision Family Tree refused to return the earnest money. Skyco then sued for return of the earnest money. The district court granted summary judgment to Family Tree. The Supreme Court reversed in part, holding that the district court (1) erred in granting summary judgment for Family Tree on Skyco's claim for return of its earnest money; and (2) properly granted summary judgment for Family Tree on Skyco's remaining claims. View "Skyco Resources, LLP v. Family Tree Corp." on Justia Law

The Supreme Court dismissed Mother's appeal from two juvenile court permanency and review orders and from the juvenile court's decision denying her motion to close the case for want of jurisdiction, holding that none of the juvenile court orders from which Mother appealed were appealable orders.The State filed a neglect petition alleging that Mother neglected her child. As the case progressed, the juvenile court held review and permanency hearings, in connection with which it issued orders. Mother appealed two of those orders and the denial of her motion to close the case. The Supreme Court dismissed the appeal, holding that the orders appealed from did not affect Mother's substantial rights and were not appealable. View "JW v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of sexual abuse of a minor in the second degree, holding that Defendant failed to establish that the district court committed plain error by allowing certain testimony.On appeal, Defendant argued that plain error occurred during trial when the district court allowed State witnesses to vouch for the credibility of other State witnesses and/or to offer opinions as to Defendant's guilt. The Supreme Court disagreed and affirmed, holding (1) the State's witnesses did not vouch for the credibility of other witnesses or offer opinions as to Defendant's guilt; and (2) in the absence of any error, the cumulative error doctrine did not apply. View "Ingersoll v. State" on Justia Law