Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court reversed the child support order requiring Father to pay post-majority support for his child, Zao, while Zao was attending college, holding that the district court abused its discretion when it ordered post-majority support.At issue was the second motion to modify support filed by the Department of Family Services, Child Support Enforcement Division. The trial court found that Zao suffered from phenylketonuria, a metabolic disorder that required a special diet and rendered Zao disabled and incapable of self-support. The court then ordered Father to continue paying support of $375 per month after high school as long as Zao was enrolled in full-time college. The Supreme Court reversed, holding that the district court's findings were unsupported by the evidence. View "O'Roake v. State, ex rel. Department of Family Services" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgments of the district court granting in part and denying in part Mother's fifth motion for order to show cause and finding Father in contempt of court upon Mother's sixth motion to show cause, holding that the district court abused its discretion in awarding Mother $100 in attorney fees.After Mother and Father divorced Mother filed several post-divorce motions in the district court. At issue was her latest two motions - her fifth and sixth motion for order to show cause why Father should not be held in contempt for allegedly harassing communications since their divorce. The district court granted in part Mother's fifth motion and awarded her $100 in attorney fees. Upon Mother's sixth motion to show cause the district court found Father in contempt of court and awarded Mother attorney fees. The Supreme Court primarily affirmed, holding that the district court (1) did not violate Mother's due process rights in refusing to consider Mother's exhibits at the hearing on the fifth motion; (2) did not err when it refused to visit its ruling on the fifth motion; and (3) abused its discretion when it awarded Mother $100 in attorney fees related to her fifth motion without explanation. View "Heimer v. Heimer" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment to Defendant Gerald James on his quiet title claim and granting both Defendants summary judgment on Plaintiffs' remaining claims, holding that summary judgment was properly granted.Plaintiffs, Robert and Naomi James, filed a complaint asserting multiple claims against Defendants, Gladys Winkel and Gerald, including a claim to quiet title to real property. Gerald answered and filed several counterclaims. Winkel answered separately and also filed a counterclaim. The district court granted summary judgment generally in favor of Defendants. The Supreme Court affirmed, holding (1) the district court did not err in ruling that Plaintiffs could not maintain a claim for equitable conversion because they failed to timely plead it; and (2) genuine issues of material fact did not preclude the grant of summary judgment to Defendants on Plaintiffs' claims. View "James v. Winkel" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of third-degree sexual assault and sentencing him to a sentence of five to eight years in prison, holding that there was no error in the proceedings below.Defendant entered an Alford plea to third-degree sexual assault. On appeal, Defendant argued two arguments relating to his competency at sentencing. The Supreme Court affirmed, holding (1) the district court did not err in imposing Defendant's sentence without first making an oral finding that Defendant was competent to proceed; and (2) the district court did not err by making a written finding that Defendant was competent to proceed with sentencing rather than sua sponte suspending the sentencing hearing and ordering him to undergo a third competency evaluation. View "Merlak v. State" on Justia Law

The Supreme Court affirmed the order of the district court granting the Wyoming Department of Family Service's petition to terminate Father's and Mother's parental rights under Wyo. Stat. Ann. 14-2-309(a)(iii) and (a)(v), holding that there was sufficient evidence for the district court to terminate Mother's and Father's parental rights.After a four-day bench trial, the district court held that the Department proved, by clear and convincing evidence, that Mother's and Father's parental rights should be terminated under sections 14-2-309(a)(iii) and (v) and that it was in the child's best interest to terminate their parental rights. The Supreme Court affirmed, holding (1) the district court had subject matter jurisdiction; and (2) the Department presented sufficient evidence for the district court to terminate Mother's and Father's parental rights under section 14-2-309(a)(v). View "Hood v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for attempted second-degree murder, felony property destruction, and other offenses, holding that the district court did not err when it denied Defendant's motion for judgment of acquittal.On appeal, Defendant argued that there was insufficient evidence to support his convictions for property destruction and felony possession of methamphetamine. The Supreme Court disagreed, holding (1) the district court did not err in denying Defendant's motion for a judgment of acquittal on the two property destruction counts because Defendant's conduct provided the required mens rea to impose criminal liability; and (2) the evidence was sufficient for the jury to determine beyond a reasonable doubt that Defendant was guilty of felony possession of methamphetamine. View "Childers v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of strangulation of a household member, holding that there was no error in the district court's evidentiary rulings.On appeal, Defendant argued, among other things, that the district court abused its discretion by admitting recorded phone calls into evidence. As to this evidence, the district court made only a cursory Wyo. R. Evid. 404(b) ruling and did not review any of the Gleason factors. The Supreme Court affirmed, holding (1) Defendant was not prejudiced by the district court's decision to admit evidence that Defendant violated a no-contact order when he called the victim from jail; and (2) the district court did not err when it admitted the victim's hearsay statement recorded on the responding officer's body cam as an excited utterance. View "Jackson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder, holding that the opinion testimony of a forensic pathologist did not materially prejudice Defendant's defense.On appeal, Defendant argued that the district court abused its discretion by admitting improper Wyo. R. Evid. 404(b) of a previous 911 call and surrounding events from 2011 and that the prosecutor's question eliciting the opinion of the forensic pathologist that the cause of death was homicide was plain error. The Supreme Court disagreed, holding (1) the district court did not abuse its discretion when it admitting evidence surrounding the 911 call; and (2) there was no reasonable probability that, absent the prosecutor's question to the forensic pathologist on the cause of death, the verdict would have been more favorable to Defendant. View "Klingbeil v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of three counts of third-degree sexual abuse of a minor between the ages of thirteen and fifteen years, holding that the district court did not improperly instruct the jury on Defendant's theory of defense that he reasonably believed the victim was at least sixteen years old.Specifically at issue was whether the district court erred by defining "reasonable belief" for the jury and by refusing to instruct the jury on the details of Defendant's theory of defense. The Supreme Court affirmed, holding (1) even if the district court erred by providing the definition of "reasonable belief" to the jury, Defendant failed to explain how he was prejudiced by the instruction; and (2) the district court did not err by refusing to provide additional details of Defendant's theory of defense. View "Bernal-Molina v. State" on Justia Law

The Supreme Court reversed the judgment of the district court entering an order requiring shared custody of a child between Mother and Father, holding that the district court erred.Father and Mother shared a child. Father filed a petition to establish custody, visitation, and child support. The district court entered a temporary custody order establishing fifty-fifty shared custody. Two years later, each parent asked for primary physical custody and requested written findings of fact and conclusions of law pursuant to Wyo. R. Civ. P. 52(a). More than one year after the bench trial, the district court entered an order requiring shared custody. The Supreme Court reversed, holding (1) the district court's delay in issuing the final order was not reversible error; but (2) the district court abused its discretion in holding that the law favors shared custody and in ordering shared custody without adequate Rule 52(a)(1)(A) findings and conclusions explaining how the arrangement was in the child's best interest. View "Castellow v. Pettengill" on Justia Law