Justia Wyoming Supreme Court Opinion Summaries

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

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