Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the district court terminating Kevin and Darcy Guilles' co-guardianship of DEP, the child of Diona Palu, holding that the Guilles failed to provide an adequate record to review the issues raised on appeal.On appeal, the Guilles asserted that the district court deprived them of due process by not providing them notice that it intended to address Palu's motion to terminate the guardianship at a scheduled hearing and that the court's parental fitness finding was contrary to the great weight of the evidence. The Supreme Court affirmed, holding that the record on appeal was inadequate to review either the Guilles' due process claim or the district court's parental fitness finding. View "In re Guardianship of DEP" on Justia Law

The Supreme Court affirmed the order of the district court holding Mother in contempt for denying Father visitation with their child during summer and for the Thanksgiving holiday, holding that there was no error.On appeal, Mother argued that the district court erred in determining that she willfully violated the divorce decree. Specifically, Mother argued that she could not have willfully violated the decree because it was no clear, specific, and unambiguous about summer visitation or about how to conduct holiday visitation during a global pandemic. The Supreme Court affirmed, holding that the district court did not err when it found Mother in contempt for denying Father summer and Thanksgiving visitation. View "Burrow v. Sieler" on Justia Law

The Supreme Court affirmed the district court's denial of Defendant's pre-sentence motion to withdraw guilty plea, holding that there was no error in the proceedings below.In 2020, the State filed a third petition to revoke Defendant's probation. Following the revocation proceeding, Defendant filed a motion to withdraw the guilty plea he had entered in 2017 on the grounds that the testimony he gave to support his plea was insufficient to establish a factual basis. The district court denied the motion. Thereafter, the court entered an order revoking Defendant's probation and entered judgment convicting him of burglary. The Supreme Court affirmed, holding that the district court properly denied Defendant's motion to withdraw his guilty plea because a sufficient factual basis existed for the plea. View "Reid v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the determination of the Medical Commission Hearing Panel that Scott Triplett failed to meet his burden to show entitlement to a right hip replacement, holding that the Medical Panel's decision was neither arbitrary or capricious.The Medical Panel determined that Triplett did not meet his burden of proof to establish that the hip replacement surgery was a reasonable and necessary medical treatment for any injury related to his work injury. The district court affirmed. The Supreme Court affirmed, holding that the Medical Panel's determination was supported by substantial evidence and was not arbitrary, capricious, or otherwise contrary to law. View "Triplett v. State, ex rel. Department of Workforce Services" on Justia Law

The Supreme Court affirmed the judgment of the juvenile court ordering that a permanency plan for minor siblings IM, NM, and AM be changed to adoption and finding that the Department of Family Services (DFS) be relieved of making further reasonable efforts to reunify, holding that there was no error.DFS recommended changing the minor siblings' permanency plan from a concurrent plan of adoption or reunification to adoption. After an evidentiary hearing, the juvenile court ordered that the permanency plan be changed to adoption and ruled that DFS could cease making reasonable efforts to reunify. The Supreme Court affirmed, holding (1) the juvenile court did not err in ruling that DFS could cease reasonable efforts following a change in the permanency plan to adoption; and (2) the admission of DFS's Exhibit A did not violate Mother's right to due process. View "RR v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming Defendant's license suspension, holding that law enforcement officers did not deprive Defendant of his right to an independent chemical test of his blood alcohol content, and therefore, his statutory and due process rights were not violated.Defendant was arrested for driving while under the influence of alcohol. Defendant submitted to a chemical breath test, which indicated that his blood alcohol concentration exceeded the legal limit. Defendant was advised of his right to obtain an independent chemical test at his own expense, and Defendant chose to exercise it. Defendant, however, never obtained the test. The Wyoming Department of Transportation suspended Defendant's driver's license for ninety days. Both the Office of Administrative Hearings and district court upheld the suspension. The Supreme Court affirmed, holding (1) substantial evidence supported the finding that law enforcement officers did not interfere with Defendant's right to obtain an independent blood test; and (2) the relevant statutes and substantive due process did not require law enforcement officers to do more than allow Defendant to go to the nearest hospital or clinic to obtain a test. View "Johnson v. State ex rel., Wyoming Department of Transportation" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court in this divorce case awarding Husband all of the interest in his business and ordering him to pay Wife $100,000 to equalize the property distribution and allowing Wife to take the parties' child to church during Husband's visitation, holding that the judgment against the business was in error.Specifically, the Supreme Court held that the district court (1) did not abuse its discretion by assigning a value to Husband's business; (2) did not abuse its discretion by requiring Husband to make the equalization payment to Wife within 120 days of the divorce; (3) erred by awarding a judgment against Husband's business, a nonparty to the divorce proceeding; and (4) did not violate Husband's constitutional rights to parent or to freedom of religion by allowing Wife to take the child to church during Husband's visitation time. View "Snyder v. Snyder" on Justia Law

The Supreme Court affirmed the judgment of the district court granting the State's petition to revoke Defendant's probation, holding that the district court did not abuse its discretion.Defendant pled guilty to conspiracy to deliver methamphetamine. The district court sentenced Defendant to three to four years of imprisonment but suspended his sentence on the condition that he successfully complete three years of supervised probation. The State subsequently petitioned to revoke Defendant's probation, claiming that Defendant violated a condition in his judgment and sentence. After a hearing, the court revoked Defendant's probation and sentenced him to a term of imprisonment. The Supreme Court affirmed, holding that there was no error or abuse of discretion. View "Farthing v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree murder, holding that Defendant's trial counsel was not ineffective for failing adequately to advise Defendant regarding his right to testify and in failing to present a defense.On appeal, Defendant challenged the district court's denial of his motion for a new trial, arguing that his trial counsel was deficient for denying him the ability to make a knowing and voluntary waiver of the right to testify and for failing to develop and prepare a defense. The Supreme Court affirmed, holding (1) Defendant made a knowing and voluntary decision not to testify; and (2) Defendant's failure to testify was not prejudicial. View "Richmond v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court determining that ASM, a middle-aged woman, needed to be involuntarily hospitalized pursuant to Wyo. Stat. Ann. 25-10-110 because she was mentally ill, as defined under section 25-10-101(a), holding that the district court did not err.Specifically, the Supreme Court held (1) upon review of the entire evidence, including ASM's testimony, the district court did not err when it found ASM to be mentally ill; and (2) the district court did not deny ASM her constitutional right to free exercise of religion under the United States and Wyoming constitutions when it ordered her involuntarily hospitalization in what ASM characterized as a "Catholic ritual of mortification" because ASM failed to establish that she was engaged in such a practice when she injured herself. View "ASM v. State" on Justia Law