Justia Wyoming Supreme Court Opinion Summaries

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

The Supreme Court affirmed Defendant's conviction of first-degree murder, holding that there was no prejudicial error in the proceedings below.After a four-day trial, a jury convicted Defendant of first-degree murder. The district court sentenced Defendant to life imprisonment. The Supreme Court affirmed, holding (1) the circuit court did not err when it determined that Defendant was competent and fit to proceed; (2) the district court did not err when it determined that Defendant's statements to law enforcement were voluntarily made; and (3) there was sufficient evidence of premeditation for a jury to convict Defendant of first-degree murder. View "Snyder v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of obtaining property by false pretenses and ordering her to pay restitution, holding that there was no error in the restitution order.Based on her failure to disclose that she and her children were living with the father of two of her three children, Defendant received overpayments of supplemental nutrition and child care assistance. Defendant pled guilty to obtaining property by false pretenses, received a deferred prosecution, and was ordered to pay restitution. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in awarding restitution that included overpayments for time period during which Defendant asserted she was eligible for assistance; and (2) Defendant waived the question of whether the district court erred when it ordered restitution that included benefits attributable to the father's income. View "Belanger v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court modifying the court's divorce decree and awarding Father primary physical custody of the parties' son, holding that there was no error.In the divorce decree, the court awarded the parties joint legal custody of the child and gave Mother primary physical custody. Mother subsequently filed a petition to modify custody. In response, Father counterclaimed for custody modification, requesting primary legal and physical custody of the child. After holding an evidentiary hearing, the district court awarded the parties joint custody of the child and Father primary physical custody. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in denying Mother's motion to remove and replace the guardian ad litem for the custody modification proceedings; and (2) adequately considered Mother's abuse allegations prior to modifying custody. View "Hays v. Martin" on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment in favor of Security State Bank (SSB) and dismissing Plaintiff's complaint asserting a first priority equitable lien on certain ranch property, holding that the district court did not err.Plaintiff loaned his friends, the Waymans, $100,000 to make a down payment on a ranch. After the Waymans defaulted on their mortgage the lender, SSB, sold the property at a foreclosure sale. In an effort to recover the $100,000 down payment, Plaintiff sued SSB, asserting a first priority equitable lien on the ranch property. The district court granted summary judgment for SSB. The Supreme Court affirmed, holding that the district court (1) did not erroneously convert SSB's motion to dismiss into a motion for summary judgment; and (2) did not err when it determined that there was no genuine issue of material fact regarding SSB's superior priority mortgage on the ranch property. View "Martin v. Security State Bank" on Justia Law

The Supreme Court denied Wyoming Cardiopulmonary Services's (WCS) motion to dismiss this appeal of the district court's confirmation of the decision of an arbitration panel concluding that the parties' non-compete agreement was enforceable if modified and reversed the confirmation of the panel's decision, holding that the panel made a manifest error of law.Dr. Michel Skaf, a cardiologist, signed a non-compete agreement when he became a shareholder in WCS. After WCS terminated Dr. Skaf for cause, he set up his own practice. WCS subsequently brought this complaint and a motion to compel arbitration. The panel found that the covenant not to compete was enforceable if modified and rewrote the agreement. The district court confirmed the panel's decision to enforce the covenant not to compete and entered judgment of $193,000. The Supreme Court reversed and vacated the award, holding that the panel made a manifest error of law in violation of public policy in its review and revision of the covenant not to compete. View "Skaf v. Wyoming Cardiopulmonary Services, P.C." on Justia Law

The Supreme Court affirmed Defendant's convictions of one count of aiding and abetting attempted second-degree murder, one count of reckless endangering, and one count of misdemeanor possession of methamphetamine, holding that the district court did not err in denying Defendant's request for a jury instruction on the lesser-included offense of accessory to attempted voluntary manslaughter.Defendant was a passenger in her co-defendant's vehicle when the co-defendant led law enforcement on a high speed chase. Defendant was convicted for her part in the crimes committed. The Supreme Court affirmed Defendant's convictions but remanded for correction of the district court's written sentencing order, holding (1) the district court did not err when it declined to give Defendant's proposed jury instruction on the lesser-included offense of accessory to attempted voluntary manslaughter; and (2) the court's written sentencing order deviated from its oral pronouncement. View "Jacobs v. State" on Justia Law

The Supreme Court affirmed the decision of the district court to grant Father's petition to modify child support, holding that the district court did not improperly impute Mother's net monthly income at $3,975.In 2018, the district court modified the parties' original parenting agreement as to their child and ordered Mother to pay child support to Father in the amount of $245 per month. In 2019, Father filed a petition to modify child support, asserting that Mother's income had increased, thus warranting a change in child support. The district court calculated a presumptive child support obligation for both parents and found Mother's share of the total presumptive child support obligation to be $597 per month. The Supreme Court affirmed, holding that the district court did not abuse its discretion in imputing the parties' respective incomes for child support purposes. View "Snowden v. Jaure" on Justia Law

The Supreme Court affirmed the judgment of the district court clarifying an order it entered in 2017 dividing the Aimone Ranch into two parcels, holding that the district court properly clarified its 2017 order under Wyo. R. Civ. P. 60(a) and denied Rex Snyder's remaining claims.As part of Rex and Ronda Snyder's divorce proceedings, the district court divided the Aimone Ranch into two parcels. The order, however, did not specify the dividing line between the parcels, nor did it address fencing. In 2019, Rex built a fence to separate the parcels, and Ronda refused to pay half the fencing costs. Rex filed a motion seeking to enforce the 2017 order and requesting that the court order Ronda to accept a quit claim deed for her parcel as fenced, accept an easement over his parcel, and reimburse him for half the fencing costs. The district court clarified its 2017 order and denied Rex's remaining claims. The Supreme Court affirmed, holding that there was no error. View "Snyder v. Snyder" on Justia Law