Justia Wyoming Supreme Court Opinion Summaries

In this divorce case, the Supreme Court affirmed the judgment of the district court holding that Appellant's claim for recoupment was barred by res judicata, holding that the district court did not err.Under the parties' stipulated divorce decree, Appellant was awarded the marital home and Appellee was ordered to execute a waiver of homestead. The cash payment provision required that Appellant pay Appellee $23,000. Appellant later filed an action seeking a declaration that the $23,000 judgment no longer operated as a lien against the marital home. The district court dismissed Appellant's complaint for failure to state a claim. Appellee subsequently filed a petition to revive the $23,000 judgment. In response, Appellant asserted a claim for recoupment. The court granted the Appellee's petition and ruled that res judicata barred Appellant's recoupment claim. The Supreme Court affirmed, holding that the district court correctly found that Appellant's claim was barred by res judicata. View "Motylewski v. Motylewski" on Justia Law

The Supreme Court dismissed this appeal for want of jurisdiction, holding that no final order had been entered in this matter.The co-personal representatives of the Estate of Gale S. Iverson sued Cheri Eaton, Iverson's former caretaker, seeking to recover property that the Estate alleged Eaton unlawfully transferred to herself. The Estate requested that Eaton be ordered to provide the Estate an accounting. Eaton, in turn, sued the Estate in a separate action for breach of express and implied contract and quantum meruit. The district court consolidated the actions, denied Eaton's claims, and ordered that Eaton provide the Estate an accounting. Eaton appealed. The Supreme Court dismissed the appeal for want of jurisdiction, holding that no final order had been entered in this matter. View "Davidson-Eaton v. Iversen" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree murder and aggravated assault, holding that the district court did not err in denying Defendant's motion to suppress statements he made at the scene of the crime and during a recorded interview.On appeal, Defendant argued that the admission of the challenged statements violated his rights under the Fifth and Fourteenth Amendment because he was not informed of his Miranda rights before he was questioned and because he was under the influence of methamphetamine at the time of the recorded interview. The Supreme Court affirmed, holding that the district court (1) did not err when it found Defendant's statements at the scene fell under the public safety exception to Miranda; and (2) did not err when it found that Defendant voluntarily waived his Miranda rights at the police station. View "Schwartz v. State" on Justia Law

The Supreme Court reversed the decision of the district court denying Plaintiff attorney fees and costs after dismissing this declaratory judgment action as moot, holding that the court erred in concluding that Plaintiff was not entitled to his attorney fees and costs.Plaintiff brought a declaratory judgment action asking the district court to declare that he had the right to install underground fiber optic cable within a utility easement located on Defendants' property. Defendants subsequently moved for judgment on the pleadings, claiming that Defendant had the right to install the fiber optic cable within the easement and that the case was now moot because there was no longer a justiciable controversy. The district court agreed, dismissed the action, and denied attorney fees and costs. The Supreme Court reversed, holding that Plaintiff was entitled to his attorney fees and costs under the easement's fee-shifting provision. View "Levy v. Aspen S, LLC" on Justia Law

The Supreme Court affirmed in part and dismissed part the judgment of the district court denying summary judgment in favor of the Wyoming State Hospital on Plaintiffs' claims asserting various claims of negligence under the Wyoming governmental Claims Act, Wyo. Stat. Ann. 1-39-101 - 120, holding that section 1-30-110's waiver of governmental immunity is not limited to medical malpractice claims.In denying the Hospital's motion for summary judgment, the district court concluded (1) the Hospital had waived its immunity under section 1-39-110, and (2) genuine issues of material fact precluded summary judgment. The Supreme Court affirmed in part and dismissed in part, holding (1) because it did not involve the purely legal issue of whether the Hospital was immune from suit under the Claims Act, the Hospital's appeal with respect to section 1-39-118 and proximate cause is dismissed for lack of jurisdiction; and (2) the district court did not err in concluding that the Hospital had waived its immunity under section 1-39-110. View "Wyoming State Hospital v. Romine" on Justia Law

The Supreme Court remanded this criminal case to the district court sentencing Defendant for methamphetamine possession, holding that this Court could not reach the issue on appeal of whether the district court erred when it used Defendant's prior Missouri conviction as a basis for an enhanced sentence under Wyo. Stat. Ann. 35-7-1031(c)(i).Defendant entered into a conditional guilty plea agreement reserving the right to appeal his conviction based on his argument that his prior Missouri convictions did not subject him to enhanced penalties b because they were not violations of a "similar law" under the Wyoming statute. The Supreme Court remanded the case for further proceedings, holding that the Court could not determine from the record which statutes or ordinances underlay Defendant's prior convictions. View "Stanger v. State" on Justia Law

The Supreme Court affirmed the orders of the district court denying Appellant's motions to correct an illegal sentence and to withdraw his guilty pleas, holding that the district court did not err.Appellant was serving consecutive life sentences for crimes he committed in Washakie County and Carbon County. In these consolidated appeals, Appellant (1) challenged the Washakie County District Court orders denying his motions to correct an illegal sentence and to withdraw his guilty plea and (2) appealed Carbon County District Court orders imposing sentences consecutive to his Washakie County sentence and denying his Wyo. R. Crim. P. 21 motion. The Supreme Court affirmed the Carbon County sentence and the denial of Appellant's Rule 21 motion, holding (1) the Washakie County District Court lacked jurisdiction to consider Defendant's arguments; (2) the Carbon County sentence did not create an unconstitutional de facto life sentence; and (3) Defendant received effective assistance of counsel at his Carbon County resentencing hearing. View "Sides v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for possession of a controlled substance, holding that the district court did not err in denying Defendant's motion to suppress under the Fourth Amendment to the United States Constitution and Wyo. Const. art. I, 4.A highway patrol trooper stopped Defendant when he twice observed Defendant's vehicle cross the dotted center white line separating the two lanes of traffic. Marijuana was found in a free-air K-9 sniff during the stop. In his motion to suppress, Defendant argued that his failure to maintain a single lane of travel on the two occasions did not create reasonable suspicion justifying the stop of his vehicle. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the district court did not err in concluding that reasonable suspicion supported the initial stop. View "Elmore v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree sexual assault, holding that there was no error in the proceedings below but that remand was required for correction of a clerical error contained in the judgment and sentence.Specifically, the Supreme Court held (1) the district court did not err in denying Defendant's motion for a new trial because Defendant failed to show that trial counsel was constitutionally ineffective; (2) there was sufficient evidence to support a conviction of sexual assault in the first degree; and (3) the district court did not abuse its discretion in using a special verdict form that required the jury to answer questions related to the charged offense before it was required to make a finding of guilt. View "Neidlinger v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that Defendant was eligible to petition for relief from the duty to register as a sex offender only if he had been registered for twenty-five years, holding that the district court did not err.Thirteen years after his conviction of four-degree sexual assault, now codified as third-degree sexual assault, Defendant began registering as a sex offender when he learned he was obligated to do so by a change in the statute. Twenty-five years after his conviction, Defendant filed a petition seeking to be relieved of the duty to register. The district court granted the petition. When the Division of Criminal Investigation moved for relief from the judgment the district court. The district court granted the motion, holding that Defendant was eligible for relief only after he had been registered for twenty-five years. The Supreme Court affirmed, holding (1) the district court did not err when it interpreted the Wyoming Sex Offender Registration Act (WSORA); (2) the WSORA is not an ex post facto punishment; and (3) Defendant failed to raise a timely or cogent claim that the WSORA violated his constitutional right to protection. View "Harrison v. State" on Justia Law