Justia Wyoming Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the district court ruling that Charlene Hassler had breached a court-modified agreement and granting summary judgment for Circle C Resources on its breach of a noncompete agreement claim, holding that the blue pencil rule is no longer permitted to make noncompete agreements reasonable.When she was hired by Circle C as a nursing assistant Hassler signed a noncompetition agreement prohibiting Hassler from soliciting Circle C's clients for twenty-four months after their employment relationship ended. After Hassler was hired by a new provider Circle C brought this action seeking damages for breach of the noncompete agreement. The district court granted summary judgment for Circle C, concluding that the noncompete agreement was reasonable enforceable if the geographical area subject to restriction were narrowed. The court then narrowed the restrictions accordingly. The Supreme Court reversed, holding (1) this Court no longer permits use of the blue pencil rule to make noncompete agreements reasonable; and (2) because the duration and geographical terms of the noncompete agreement were unreasonable the entire agreement was void in violation of public policy. View "Hassler v. Circle C Resources" on Justia Law

The Supreme Court affirmed the judgment of the district court dividing the marital property of Husband and Wife, holding that the district court did not abuse its discretion in its division of marital property.After a bench trial, the district court entered a decree of divorce that resolved credibility issues against Husband and awarded an equalization payment to Wife. Husband appealed, arguing that the property division and equalization payment were unfairly punitive. The Supreme Court affirmed, holding that the district court did not abuse its discretion in the manner in which it disposed of the marital property at issue in this case. View "Morrison v. Rubio" on Justia Law

The Supreme Court affirmed the order of the juvenile court changing the permanency plan for Mother and Father's children, SMD and SND, from reunification to adoption, holding that the juvenile court did not abuse its discretion.Specifically, the Supreme Court held that the juvenile court (1) did not abuse its discretion when it found that it was in the children's best interests to change the permanency plan to adoption instead of guardianship; and (2) did not abuse its discretion when it determined there was no need for a concurrent plan of reunification upon determining that reunification efforts could cease. View "In re Interest of SMD" on Justia Law