Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court dividing marital property between Wife and Husband upon granting Husband a divorce, holding that the district court did not abuse its discretion by dividing the marital property as it did.On appeal, Wife argued that the district court abused its discretion by arbitrarily awarding her an equalization payment of $200,000 and requested that the Court either modify the judgment to $334,789 or remand for further proceedings. The Supreme Court affirmed, holding that the district court did not abuse its discretion in awarding the property in a division it considered fair and equitable and after applying the factors set forth in Wyo. Stat. Ann. 20-2-114. View "Innes v. Innes" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of State Farm Mutual Automobile Insurance Company and dismissing Plaintiffs' claim alleging that they were entitled to uninsured motor vehicle (UIM) benefits after they were injured in an automobile accident caused by another driver, holding that State Farm was entitled to judgment as a matter of law.After their accident, Plaintiffs filed claims with State Farm for full UIM benefits of $100,000 after settling with the tortfeasor's insurance company. When State Farm did not respond, Plaintiffs brought suit, asserting breach of contract, bad faith in delaying and denying payment for the benefits, and breach of the implied covenant of good faith and fair dealing. The district court granted summary judgment for State Farm. The Supreme Court affirmed, holding that under the unambiguous language of the State Farm insurance policy, Plaintiffs were not entitled to UIM benefits and were not entitled to relief on their claims. View "Bergantino v. State Farm Mutual Automobile Insurance Co." on Justia Law

The Supreme Court affirmed the order of the district court denying Appellant's motion to correct an illegal sentence, holding that Appellant's claim of an illegal sentence based on the facts supporting his conviction was barred by res judicata.Appellant pled guilty to escape and was sentenced to a two-to-three-year sentence to run concurrent with sentences Appellant had received for other crimes. Appellant later sent a letter that the district court interpreted as a motion to correct illegal sentence under Wyo. R. Crim. P. 35(a). The district court denied the motion as barred by the doctrine of res judicata. The Supreme Court affirmed, holding that Appellant's claim was barred by res judicata because he could have raised the issue in an earlier proceeding. View "Majhanovich v. State" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of Sweetwater County School District No. 1 and dismissing Plaintiff's negligence claim, holding that genuine issues of material fact did not preclude summary judgment in favor of the School District.Plaintiff, through his mother as next friend, brought this action claiming that he suffered a traumatic brain injury when he fell and struck his head on a PVC pipe that had been placed across a concrete walkway outside his elementary school building to divert water away from the building. Plaintiff claimed that the negligent placement of the pipes across the walkway created a dangerous condition, causing his injury. The district court granted summary judgment in favor of the School District. The Supreme Court affirmed, holding that the district court properly granted the School District summary judgment. View "Miller v. Sweetwater County School District #1" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to transfer his case to juvenile court, holding that the district court did not abuse its discretion in denying the motion to transfer the case to juvenile court.Defendant, a minor, was arrested and charged with nine counts of attempted first-degree minor after taking guns and ammunition to his high school planning to shoot nine particular individuals and as many other people as he could. Defendant filed a motion to transfer his case to juvenile court, but the motion was denied. The Supreme Court affirmed, holding that the district court appropriately analyzed and weighed the applicable factors under Wyo. Stat. Ann. 14-6-237(b) and did not abuse its discretion in denying Defendant's motion to transfer. View "Warner v. State" on Justia Law

In this property dispute, the Supreme Court reversed in part the judgment of the district court granting summary judgment to the Hogback Ranches Property Owners Improvement and Service District (HRISD) on the issue of whether HRISD violated the Hoback Ranches subdivision's protective covenants by installing wire fencing around the subdivision's perimeter and otherwise affirmed, holding that the district court erred in part.Plaintiffs, who resided in the subdivision, brought suit against HRISD and their neighbor, Michael Jerup, alleging, inter alia, that HRISD violated the subdivision’s protective covenants with its perimeter fence and that Jerup violated the covenants by conducting commercial activity on his property. HRISD and Jerup counterclaimed, alleging that Plaintiffs violated the protective covenants by installing wood posts set in concrete. The district court (1) granted summary judgment to HRISD on Plaintiffs' claims; (2) granted summary judgment to HRISD and Jerup on their counterclaim; and (3) entered judgment for Jerup on Plaintiffs' claim. The Supreme Court reversed the district court's summary judgment to HRISD on the perimeter fence issue and otherwise affirmed, holding that the district court erred in deciding that a buck and pole fence covenant did not apply to the subdivision's perimeter fence. View "Winney v. Hoback Ranches Property Owners Improvement & Service District" on Justia Law

The Supreme Court affirmed the decision of the Office of Administrative Hearings (OAH) upholding the decision of the Wyoming Department of Transportation (WYDOT) suspending Defendant's driver's license and operating privileges pursuant to Wyo. Stat. Ann. 31-6-102(e), holding that the OAH reasonably concluded as it did.Defendant was arrested for driving under the influence of alcohol. Because a breathalyzer test indicated that Defendant had a blood alcohol concentration greater than .08% the WYDOT suspended Defendant's driver's license. The OAH upheld the suspension. The Supreme Court affirmed, holding that substantial evidence supported the OAH's finding that law enforcement did not interfere with Defendant's right to obtain an independent chemical test under Wyo. Stat. Ann. 31-6-102(a)(ii)(C) and 31-6-105(d). View "Flauding v. State ex rel. Wyoming Department of Transportation" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of aggravated assault and battery, holding that prosecutorial misconduct did not prejudice Defendant.At trial, Defendant requested that the jury be instructed on self-defense. On appeal, Defendant argued that the prosecutor committed misconduct at trial when she misstated the law of self-defense to the jury three different times. The Supreme Court affirmed, holding that the prosecutor in this case did not misstate the law and that Defendant failed to show how the prosecutor's comments, considered cumulatively, prejudiced him. View "Mendoza v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of eight counts of forgery, holding that the district court did not err or abuse its discretion.On appeal, Defendant argued that the evidence was insufficient to show an intent to defraud and that the district court erred in instructing the jury on the required intent to defraud. The Supreme Court affirmed, holding that the district court (1) did not err in denying Defendant's motion for judgment of acquittal; and (2) did not abuse its discretion when it instructed the jury on the required element of intent to defraud. View "Bezold v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree sexual abuse of a minor, holding that the district court did not violate Defendant's right to a speedy trial.The State originally charged Defendant with one count of first-degree sexual assault and one count of delivery of a controlled substance, but sixteen days before trial, the State amended its information to include one count of second-degree sexual abuse of a minor. After a jury trial, Defendant was found guilty of second-degree sexual abuse of a minor. The Supreme Court affirmed, holding (1) Defendant's argument that the amendment to the indictment was untimely was waived because he failed to raise it below; and (2) Defendant was not deprived of his right to a speedy trial. View "Rogers v. State" on Justia Law