Justia Wyoming Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the district court denying Defendant's request for a hearing to show cause and denying his application to remove an interlock device in his car, holding that the district court erred and abused its discretion by denying Defendant's request for a hearing.After he received his tenth driving under the influence (DUI) conviction Defendant was required to operate only vehicles equipped with an ignition interlock device. After eight years of sobriety, Defendant applied to the district court to have the interlock removed pursuant to Wyo. Stat. Ann. 31-5-233(f)(v) and requested a hearing to show cause. The district court denied both requests without explanation. The Supreme Court reversed, holding (1) section 31-5-233(f)(v) requires a court to hold a hearing to allow a defendant to show good cause after he has made a prima facie showing for relief; and (2) the district court was not required to make findings of fact and explain its reasoning. View "Schneider v. State" on Justia Law

The Supreme Court reversed the order of the district court modifying Father's child support obligation, holding that the court abused its discretion by modifying child support without first having sufficient information about Father's finances.Pursuant to an agreement incorporated into their divorce decree, Mother had primary custody of the parties' three children, and Father paid no child support. The State later petitioned to modify child support. The court entered a temporary support order on the State's petition, determining that Father's presumptive child support obligation was $832 per month. Father subsequently filed a motion seeking primary custody and an adjustment of child support. The court denied custody but modified Father's child support obligation to $134 per month. The Supreme Court reversed, holding that the district court did not have sufficient information about Father's finances and abused its discretion by modifying child support in the absence of such information. View "Tucker v. Tucker" on Justia Law

The Supreme Court affirmed the order of the district court compelling Defendant to pay $63,428 in restitution to the victim of his offense, Rafael Magana, holding that the district court did not err or abuse its discretion.Specifically, the Supreme Court held (1) the district court had the authority to award restitution to Magana; (2) there was sufficient evidence supporting the district court's award of restitution to Magana; and (3) the district court did not abuse its discretion by failing to consider Magana's comparative fault in determining the amount of restitution. View "Cave v. State" on Justia Law

The Supreme Court reversed the judgment of the juvenile court changing the permanency plan for Mother and her three children from family reunification to termination of parental rights and adoption, holding that the juvenile court abused its discretion.On appeal, Mother argued that the juvenile court abused its discretion in determining that the Wyoming Department of Family Services had made reasonable efforts to reunify Mother with her children. The Supreme Court agreed, holding that the record demonstrated that the Department failed in its burden to show that it provided Mother appropriate services or genuine help to achieve reunification with her children. View "In re MA" on Justia Law