Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed in all respects the district court's findings, conclusions, and decree of divorce in the proceedings between Father and Mother, holding that the district court did not abuse its discretion in awarding Mother physical custody of the parties' two children and in determining the child support award.After trial, the court entered its findings, conclusions, and decree of divorce. The decree awarded Mother physical custody, granting Father standard visitation rights, and ordered to pay Father child support. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in awarding Mother physical custody; and (2) the district court properly exercised its discretion in weighing the Wyo. Code Ann. 20-2-307(b) factors and in determining Father's child support obligation accordingly. View "Bruce v. Bruce" on Justia Law

The Supreme Court reversed the judgment of the district court holding that BJ lacked standing bring his petition to establish paternity and dismissing the petition, holding that a man claiming to be the biological father of a child has standing to bring a paternity action when the child has a legally presumed father.Mother gave birth to Child while married to CM, Child's presumed father. Another man, BJ, claimed to be Child's father and brought this action seeking to establish paternity. The district court concluded that BJ lacked standing under Wyo. Stat. Ann. 14-2-802 and dismissed his petition. The Supreme Court reversed, holding (1) BJ was a "man whose paternity of the child is to be adjudicated" under section 14-2-802(a)(iii); and (2) therefore, BJ had standing to bring his petition to establish paternity even where CM was legally presumed to be Child's father. View "BJ v. KM" on Justia Law

The Supreme Court reversed the decision of the district court denying Defendant's motion to suppress evidence discovered after law enforcement entered Defendant's apartment without a warrant to arrest him after he failed to stop for a traffic violation, holding that the district court erred.In denying Defendant's pretrial motion to suppress the district court concluded that the officers' warrantless entry into Defendant's apartment to arrest him was constitutional under the hot pursuit exception to the Fourth Amendment's warrant requirement. The Supreme Court reversed, holding that, under the circumstances, there was no compelling need requiring immediate police action. View "Fuller v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for aggravated animal cruelty and reckless endangering, holding that there was no error and that the evidence was sufficient to support the convictions.Defendant's convictions arose from a dog fight that resulted in a local teenager grabbing Rocky, a boxer, into the street and Defendant, the owner of the other dogs involved in the fight, shooting Rocky as he was held by the teenager. On appeal, Defendant argued that the district court erred in instructing the jury on the law of animal cruelty and that the evidence was insufficient to convict him of reckless endangering. The Supreme Court affirmed, holding (1) Defendant waived his argument that the jury instruction was confusing or misleading; (2) the district court properly denied Defendant's proposed elements instruction; and (3) the evidence was sufficient to sustain the conviction of reckless endangering. View "Mackley v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Board of Trustees of Laramie County School District Number Two (the Board) dismissing Appellant from his teaching contract with Laramie County School District Number Two (the District) after Appellant disciplined his daughter at school, holding that substantial evidence supported the Board's dismissal decision.At issue was whether district policies and professional conduct standards applied to Appellant, a teacher, who disciplined his child, a student, on school grounds during school hours. The Board concluded that those policies and standards applied to Appellant and dismissed him. The district court affirmed the dismissal and affirmed the Board's decision to pay Appellant only a pro-rata portion of extra-duty pay for coaching track and no bonus following his suspension with pay. The Supreme Court affirmed, holding (1) substantial evidence supported the Board's decision dismissing Appellant; and (2) there was no Board decision on extra-duty or bonus pay for this Court to review. View "Mirich v. State ex rel., Board of Trustees of Laramie County School District Two" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Mother's motion to set aside entry of default and vacate default hearing and modifying the parties' decree of divorce to award Father primary custody of the children, holding that the district court did not err.Father petitioned for an order modifying custody and support following Mother's relocation with the parties' minor children. Mother failed to respond, and the clerk of court entered default. Three days later, Mother moved to set aside the entry of default and to vacate the hearing. The court denied the motion and found that Father had met his burden of proving a material change in circumstances that warranted a modification in custody and support. The Supreme Court affirmed, holding that the district court did not err when it (1) denied Mother's motion to set aside entry of default and vacate default hearing; (2) precluded Mother from presenting affirmative evidence during the default hearing; and (3) modified custody. View "Rush v. Golkowski" on Justia Law

The Supreme Court reversed Defendant's conviction of being an accessory to both involuntary manslaughter and aggravated assault and battery, holding that the district court erred when it refused to instruct the jury on defense of another.On appeal, Defendant argued that the evidence created a disputed issue of fact as to whether she was an aggressor in the dispute or was acting in defense of the victim throughout the conflict. The Supreme Court agreed, holding (1) defense of another is a recognized defense in this jurisdiction, Defendant's proffered instruction correctly stated the law, and the defense was supported by competent evidence; and (2) therefore, the district court erred when it refused to instruct the jury on defense of another. View "Smith v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony attempted interference with a peace officer and misdemeanor child endangerment, holding that the evidence was sufficient to support the convictions.On appeal, Defendant argued that the officer was not engaged in the lawful performance of his official duties when he used subdued Defendant and that the evidence was insufficient to support the finding that he had the specific intent to disarm the officer. The Supreme Court disagreed, holding (1) the evidence was sufficient to support the jury's finding that the officer did not use excessive force and was therefore engaged in the lawful performance of his duties when he subdued Defendant; and (2) there was sufficient evidence to show Defendant acted with the requisite specific intent. View "Latham v. State" on Justia Law

The Supreme Court affirmed the order of the district court modifying Father's child support obligation to Mother, holding that the court did not err by modifying Father's child support obligation without requiring Mother to prove a material change in circumstances in addition to a twenty percent change in the support amount.Father commenced this action in 2019 seeking modification of child custody, visitation, and support. The parties reached an agreement on all matters in Father's petition except child support, which proceeded to trial. Applying the child support guidelines, the district court found Father's presumptive support obligation would change by more than twenty percent from the amount previously ordered in 2016, establishing a change in circumstances to justify a modification under Wyo. Stat. Ann. 20-2-311(a). The Supreme Court affirmed, holding that the heightened requirement for modification of a child support order was inapplicable and that Mother's showing of a twenty percent change in support justified the district's modification of Father's child support obligation. View "Brown v. Brown" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's Wyo. R. Crim. P. 35(b) motion for a sentence reduction, holding that the district court did not abuse its discretion.Defendant pled guilty to one count of second degree sexual abuse pursuant to a plea agreement. The district court sentenced Defendant to a prison term of twelve to fifteen years. Defendant later filed a motion for sentence reduction, citing the progress that he had made since his incarceration. The district court denied the motion. The Supreme Court affirmed, holding that Defendant's sentence was within the sentencing range, and the district court did not abuse its discretion denying a reduction. View "Coffey v. State" on Justia Law