Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the district court granting summary judgment in favor of the Board of County Commissioners of Laramie County and Laramie County Assessor Kenneth Guille (collectively, the County) and concluding that the durational residency requirement in Wyo. Stat. Ann. 39-13-105(a)(vi) is constitutional, holding that there was no error.Section 39-13-105(a)(vi) grants qualified veterans an annual property tax exemption if they have been Wyoming residents for at least three years. Plaintiff brought this action seeking a declaration that the durational residency requirement for the veteran tax exemption is unconstitutional. The district court granted summary judgment for the County. The Supreme Court affirmed, holding (1) section 39-13-105(a)(vi) does not infringe on Plaintiff's fundamental right to travel, and therefore, the rational basis test applies; and (2) the statute does not violate either the equal protection and privileges and immunities clauses of the Fourteenth Amendment or the constitutional right to interstate travel. View "Martin v. Board of County Commissioners of Laramie County" on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated assault and battery and misdemeanor interference with a peace officer, holding that there was sufficient evidence to support the conviction and that Defendant was not denied his right to a speedy trial.On appeal, Defendant argued that the evidence presented at trial was insufficient to show that he threatened to use a drawn deadly weapon on another person and that he was denied his right to a speedy trial under Wyo. R. Crim. P. 48 and the United States and Wyoming Constitutions. The Supreme Court affirmed, holding (1) the evidence was sufficient to show Defendant threatened to use a drawn deadline weapon on another person; and (2) Defendant was not denied his constitutional right to a speedy trial. View "Cotney v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion to dismiss the State's complaint seeking the forfeiture of currency the State seized from him, holding that the district court had subject matter jurisdiction over the State's forfeiture complaint.In his motion to dismiss, Appellant asserted that the circuit court had exclusive jurisdiction over the action because the amount of currency seized was less than $50,000. The district court denied the motion, finding that Wyo. Stat. 35-7-1049, the forfeiture statute, vested exclusive jurisdiction in district courts. The Supreme Court affirmed on different grounds, holding (1) the forfeiture statute does not grant exclusive jurisdiction over forfeiture actions to district courts; and (2) district courts have general jurisdiction over civil forfeiture proceedings. View "Orosco v. State" on Justia Law

The Supreme Court reversed Defendant's conviction for third-degree sexual assault and false imprisonment, holding that the district court erred in denying Defendant's motion to transfer his case to juvenile court.Defendant was eighteen years old when the State charged him with offenses that he allegedly committed when he was seventeen years old. When Defendant moved to transfer his case to juvenile court, the State argued that the juvenile court lacked concurrent jurisdiction because Defendant was an adult when the charges were filed against him. The district court dismissed Defendant's transfer motion, concluding that the juvenile court's jurisdiction depended on Defendant's age when he was charged rather than his age when he committed the offense at issue. The Supreme Court reversed, holding that a juvenile court's concurrent jurisdiction under Wyo. Stat. Ann. 14-6-203(c) depends on an offender's age at the time of the offense, rather than at the time charges are filed. View "Rosen v. State" on Justia Law

The Supreme Court reversed the judgment of the district court ruling that Western Wyoming Beverages, Inc. (WWB) would likely succeed on the merits of its claim that Jorge Malave, its employee, had breached his noncompete agreement that the WWB would suffer irreparable harm of Malave were not enjoined from continuing to work for WWB's competitor, holding that the district court erred.The district court concluded that there was a valid and reasonable noncompete agreement between the parties and that WWB would likely succeed on the merits of its claim that Malave had violated the agreement and would suffer possible irreparable injury if no injunction were entered. The Supreme Court reversed, holding that WWB did not meet its burden of proving probable success on the merits of the reasonableness of its noncompete agreement with Malave. View "Malave v. Western Wyoming Beverages, Inc." on Justia Law

The Supreme Court reversed the judgment of the district court dismissing this personal injury lawsuit as untimely, holding that the district court erred in ruling that Wyo. Stat. Ann. 1-3-118 did not apply to Plaintiff's voluntary dismissal.On October 20, 2013, Plaintiff brought this lawsuit against Defendant seeking damages for his injuries incurred in an accident with Defendant. On November 1, 2019, Plaintiff filed a motion to dismiss the case without prejudice, which the trial court granted. On July 22, 2020, Plaintiff filed a new complaint. Defendant filed a motion to dismiss, arguing that the new action was outside the four-year statute of limitations under Wyo. Stat. Ann. 1-3-105(a)(iv)(C) and that the claims were untimely under section 1-3-118. The district court granted the motion to dismiss. The Supreme Court reversed, holding that dismissal was not warranted because section 1-3-118 does not limit its application to dismissals initiated by an opposing party or sua sponte dismissals. View "Hugus v. Reeder" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony murder, second-degree murder, aggravated burglary, and possession of a deadly weapon but remanded the cause for correction of an illegal sentence, holding that the sentence for first-degree felony murder was improper.After convicting Defendant, the district court sentenced Defendant to life in prison for felony murder and ten to fifteen years for aggravated burglary. The Supreme Court affirmed Defendant's conviction but remanded for correction of a sentencing error, holding (1) defense counsel's failure to secure a second psychological evaluation and failure to timely recognize that Defendant had not performed testing did not prejudice Defendant's defense; and (2) the imposition of multiple punishments for felony murder and the underlying felony violated the Double Jeopardy Clauses of the United States and Wyoming constitutions. View "Steplock v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Medical Commission upholding the denial of Appellant's request for benefits, holding that there was substantial evidence to support the Commission's denial of coverage.In 2007, Appellant suffered a compensable injury to her left knee. More than a decade later, Appellant submitted requests to the Department of Workforce Services, Workers' Compensation Division to cover treatment for her right knee, ankles and back and further applied for permanent total disability (PTD) benefits. The Division denied both requests, and the Commission affirmed the ruling. The Supreme Court affirmed, holding that that there was substantial evidence to support the Commission's findings that (1) Appellant's right knee, ankle, and back injuries were not second compensable injuries; and (2) Appellant did not qualify for PTD benefits under the odd lot doctrine. View "Ross v. State, ex rel., Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that the lease of property in this case did not violate Appellants' first refusal to purchase the property, holding that the district court did not err.John and Melanie Lennon leased property owned by the Larry Lee Luckinbill Living Trust for a 125-year term. Thereafter, Appellants - Anne Holding and the Crandall Creek Ranch Company - brought suit against the Lennons and the trust's trustee, seeking a declaratory judgment stating that the lease violated their right of first refusal. The district court concluded that the right of first refusal remained in effect but that the lease did not trigger that right. The Supreme Court affirmed, holding that the lease did not trigger Appellants' right of first refusal. View "Holding v. Luckinbill" on Justia Law

The Supreme Court reversed the judgment of the district court granting summary judgment to the City of Lander and dismissing Plaintiffs' negligence claim on grounds of governmental immunity, holding that the district court erred both procedurally and as a matter of law when it granted summary judgment.Plaintiffs found a bat in their home and called the Animal Control Division of the Lander Police Department. The bat was captured but escaped before it could be tested for rabies. Plaintiffs filed a complaint seeking damages for the cost of the rabies vaccines and mental anguish. The trial court granted summary judgment in favor of the City. The Supreme Court reversed, holding (1) the district court procedurally erred when it granted summary judgment on grounds not raised by the parties without giving notice and a time to respond; and (2) the City was not entitled to summary judgment as a matter of law on the undisputed facts of record. View "Cornella v. City of Lander, Wyoming" on Justia Law