Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Diana Myers's Wyo. R. Crim. P. 60(b)(6) motion seeking relief from the parties' martial settlement agreement and divorce decree, holding that the district court did not abuse its discretion.In 2019, Diana and Griffin Myers divorced. In 2021, Diana filed her motion seeking relief from the settlement agreement and divorce decree on the grounds that an asset divided pursuant to the divorce was worth significantly more than Diana believed during mediation. The district court denied the motion. The Supreme Court affirmed, holding (1) Diana had no right to discovery on her Rule 60(b) motion; and (2) the district court did not abuse its discretion when it concluded that Diana's motion asserted improper grounds, was untimely, and failed to demonstrate extraordinary circumstances. View "Myers v. Myers" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence, holding that there was no error.Defendant was convicted of three counts of first-degree sexual assault, one count of kidnapping, and one count of aggravated assault and battery. The Supreme Court affirmed on direct appeal. Defendant later filed his motion to correct an illegal sentence, asserting that his sentence violated constitutional prohibitions against double jeopardy. The district court denied relief, determining that Defendant's claims were barred by res judicata and failed on the merits. The Supreme Court affirmed, holding that Defendant's motion to correct an illegal sentence was barred by res judicata. View "Harrell v. State" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence obtained after law enforcement entered her home without a warrant or consent, holding that the district court erred.Defendant entered a conditional plea of guilty to felony driving under the influence. On appeal, Defendant challenged the district court's denial of her motion to suppress, arguing that the record did not support a finding that her husband consented to a law enforcement officer's entry into their home. The Supreme Court reversed and remanded the case, holding (1) the district court erred in concluding that the officer had implied consent to enter the home; and (2) therefore, the officer violated the Fourth Amendment to the United States Constitution. View "Hawken v. State" on Justia Law

Mother sought sole legal and physical custody of the children, born in 2014 and 2018, plus child support and medical support. Father was properly served but failed to respond. The court held a default hearing. Father, who was in custody on a pending criminal matter, appeared but represented himself. Mother requested a “graduated” 15-month visitation schedule for Father, noting that had been in and out of jail, used drugs, and had unstable housing and employment. She asserted Father had been a roofer for approximately 10 years. A subsequent temporary order awarded Mother sole physical custody of the children, the parties shared legal custody, and Father paid no child support.Approximately 18 months later, Mother informed the court that Father had been released from prison. At a default hearing, Mother appeared with counsel. Father appeared but represented himself. The court heard no evidence, found it in the children’s best interest for the parties to have joint legal custody, Mother to have primary physical custody, and Father to have “reasonable, graduated visitation,” and ordered Father to pay $363 a month in child support. The Wyoming Supreme Court reversed. The court erred in ruling on visitation without any evidentiary basis to determine the children’s best interest and abused its discretion by calculating child support without having a sufficient evidentiary basis to determine Father’s income even though Mother failed to object. View "Hehn v. Johnson" on Justia Law

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