Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the district court's denial of Defendant's motion to correct an illegal sentence, holding that the district court did not err in denying Defendant's motion.After a jury trial, Defendant was convicted of attempted first-degree murder and was sentenced to prison for the remainder of his natural life. Defendant later filed his motion to correct an illegal sentence under Wyo. R. Crim. P. 35(a). The district court denied the motion without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) Defendant's arguments concerning the validity of his conviction were not reviewable in this Rule 35(a) motion; and (2) Defendant's arguments concerning the legality of his conviction and sentence were barred by res judicata. View "Best v. State" on Justia Law

The Supreme Court affirmed the decision of the district court reversing the decision of the Board of Trustees of Lincoln County School District Number Two dismissing Wyatt Earling from his teaching position pursuant to Wyo. Stat. Ann. 21-7-110(a)(ix), holding that there was no error.When Earling was hired in 2004, the District issued him an Apple laptop. Earling created an Apple ID and used that same ID on District-issued Apple devices for the next fifteen years. In 2018, personal photos and images from Earling's iPhone began synching to an iPad. When Superintendent Matt Erickson discovered inappropriate photos and images on the iPad, Earling was terminated. The district court reversed the Board's decision, concluding that substantial evidence did not support the decision. The Supreme Court affirmed, holding (1) the Board failed to furnish Earling a clear standard of conduct; and (2) the Board could not dismiss Earling for "[a]ny other good or just cause relating to the educational process" under Wyo. Stat. Ann. 21-7-110(a)(ix). View "Board of Trustees of Lincoln County School District Number Two v. Earling" on Justia Law

The Supreme Court affirmed the order of the district court denying Father's petition to modify child custody, holding that the district court did not abuse its discretion.On appeal, Father argued that the district court abused its discretion when it (1) found a material change in circumstances had occurred warranting reconsideration of child custody but then declined to modify the custody arrangement, and (2) excluded the testimony of one of Father's witnesses at trial. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in declining to modify the custody arrangement; and (2) the district court did not abuse its discretion in excluding the testimony of Father's witnesses at trial. View "Lackey v. Lackey" on Justia Law

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