Justia Wyoming Supreme Court Opinion Summaries

In this divorce action, the Supreme Court affirmed the judgment of the district court establishing joint custody of the children and failing to require Father to pay Mother retroactive child support, temporary alimony, and attorney fees and costs, holding that the district court did not abuse its discretion.Specifically, the Supreme Court held (1) the district court did not abuse its discretion by awarding the parties joint custody of the children; (2) the district court did not abuse its discretion by refusing to require Father to pay Mother retroactive child support; (3) the district court did not abuse its discretion by failing to require Father to pay Mother temporary alimony and her attorney fees and costs for the district court divorce proceedings; and (4) Father was entitled to his attorney fees and costs under Wyo. Stat. Ann. 20-2-112. View "Sears v. Sears" on Justia Law

The Supreme Court affirmed the judgment of the district court revoking Defendant's probation, holding that the district court did not abuse its discretion when it concluded that Defendant willfully violated his probation when he missed a meeting with his probation agent and used methamphetamine.In 2018, Defendant was found guilty of two counts of possession of a controlled substance. In 2020, the State moved to revoke Defendant's probation, alleging that Defendant, among other things, willfully used methamphetamine. The district court found that Defendant willfully violated his probation and revoked Defendant's probation and imposed the underlying sentence. The Supreme Court affirmed, holding that the district court's finding that Defendant willfully used and admitted to using methamphetamine was not clearly erroneous. View "Ramos v. State" on Justia Law

The Supreme Court reversed the order of the juvenile court relieving the State of Wyoming's Department of Family Services (DFS) from its statutory responsibility to make reasonable efforts to reunify Father with Child, holding that the juvenile court violated Father's due process rights by failing to give him reasonable notice and a meaningful opportunity to be heard early in the child protection action.Specifically, the Supreme Court held (1) there were several due process violations in this case stemming from Father's lack of involvement in the juvenile court action, which colored the court's determination that it was appropriate to release DFS from its obligation to reunite the family, and under the circumstances, Father was materially prejudiced by the due process violations; and (2) the juvenile court abused its discretion when it ruled that the State had proven by clear and convincing evidence that aggravating circumstances existed that would make reunification between Father and Child unlikely. View "RA v. State" on Justia Law

The Supreme Court reversed the decision of the Laramie County Planning Commission denying Asphalt Specialities Co., Inc.'s (ASCI) site plan application for a hard rock quarry operation in Laramie County, holding that the Commission's decision was unlawful and must be set aside under Wyo. Stat. Ann. 16-3-114(c)(ii).At issue on appeal was whether the Commission's decision to deny ASCI's application was in excess of statutory jurisdiction, authority or limits or lacking statutory right. The Supreme Court concluded that it was, holding that the Commission exceeded its statutory authority when it utilized its comprehensive land use plan and the site plan review process to deny ASCI use of its land for a limited gravel mining operation. View "Asphalt Specialties Co., Inc. v. Laramie County Planning Commission" on Justia Law

The Supreme Court reversed the final judgments against Plaintiffs, Australian investors, who sued Gas Sensing Technology Corporation (GSTC), a Wyoming-based oil and gas service company, for payment of loans Plaintiffs made to finance GSTC's operations in Australia, holding that the court erred in dismissing GSTC's counterclaims.The district court dismissed GSTC's counterclaims on grounds that they unduly complicated the action and were untimely filed. The jury found that Plaintiffs had breached the implied covenant of good faith and fair dealing and, therefore, awarded no damages on Plaintiffs' breach of contract claims. The Supreme Court reversed, holding (1) the district court erred in dismissing GSTC's claims on the ground that they unduly complicated the case; and (2) the court erred in failing to give effect to a pleading GSTC filed in federal court and in dismissing GSTC's counterclaims as untimely. View "Jontra Holdings Pty Ltd v. Gas Sensing Technology Corp." on Justia Law

The Supreme Court affirmed the order of the district court granting Defendant summary judgment and dismissing Plaintiff's legal malpractice claim, holding that collateral estoppel and in pari delicto barred Plaintiff's legal malpractice claim.In 2018, the district court revoked The Mattheis Company's (the Company) liquor license. In 2019, the Company sued Richard Mulligan and Mulligan Law Office, P.C. (collectively, Mulligan), for legal malpractice related to the revocation of its liquor license. The district court granted Mulligan summary judgment based on collateral estoppel. The Supreme Court affirmed, holding that collateral estoppel and in pari delicto barred the Company's legal malpractice claim. View "Mattheis Co. v. Mulligan" on Justia Law

The Supreme Court reversed the judgment of the district court declaring that Scott Smithson and Elena Morozova (the Smithsons) did not have the right to fish in the Little Laramie River, holding that a 1965 warranty deed granted a profit that was appurtenant to the Smithson tract, giving the Smithsons the right to access to fish in the Little Laramie River.The predecessors of Frederick and Stephanie Lindzey conveyed the right to fish in the Little Laramie River to the predecessors of the Smithsons. The Smithsons filed suit for declaratory judgment and an injunction preventing the Lindzeys from interfering with it, arguing that they continue to hold the right to fish because it is a servitude appurtenant to the land. The district court found in favor of the Lindzeys, declaring that any right to fish was a license that ended when the original grantees sold their interest in the land. The Supreme Court reversed, holding that the plain language of the 1965 warranty deed created a profit, and nothing in the deed or in the context of the transfer overcame the presumption that the profit was appurtenant to the Smithson tract. View "Smithson v. Lindzey" on Justia Law

The Supreme Court affirmed Defendant's convictions for three counts of first-degree sexual abuse of a minor, holding that the district court did not commit prejudicial error in admitting evidence of prior bad acts under Wyo. R. Evid. 404(b) and by refusing to conduct a pretrial taint hearing.On appeal, Defendant argued, among other things, that had the trial court considered the factors set forth in Gleason v. State, 57 P.3d 332 (Wyo. 2002) before admitting the 404(b) evidence, the evidence would not have been admissible at trial. The Supreme Court disagreed, holding (1) the admission of the 404(b) evidence did not prejudice Defendant because, even without the evidence of Defendant's prior uncharged conduct, there was no reasonable probability that the jury would have reached a different conclusion; and (2) the district court did not abuse its discretion in concluding that the victim was competent without further consideration of evidence of taint. View "Miller v. State" on Justia Law

The Supreme Court dismissed this appeal from the judgment of the district court accepting Defendant's plea of no contest to stalking but declining to enter a conviction on the plea, deferring the proceedings, and placing Defendant on one year of unsupervised probation, holding that this Court lacked jurisdiction.On February 27, 2020, the district court signed the sentencing order and, the next day, e-mailed the sentencing order to the district court. On March 3, 2020, the hard copy of the sentencing order was filed of record. On April 2, 2020, Defendant filed her notice of appeal. The Supreme Court dismissed the appeal, holding that Defendant's appeal was untimely, and therefore, this Court lacked jurisdiction. View "Raczon v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's pro se complaint filed under the Uniform Declaratory Judgments Act alleging that the Wyoming Department of Corrections (WDOC) inmate classification policies are invalid rules, holding that the WDOC's inmate classification policy is not a rule required to be filed with the Wyoming Secretary of State.Plaintiff pled guilty to kidnapping and first-degree sexual assault and was sentenced to two concurrent life sentences. In his complaint for declaratory judgment Plaintiff alleged that the failure to file WDOC policies and procedures with the Secretary of State rendered them, and any actions taken pursuant to them, void. Therefore, Plaintiff claimed that his recent inmate classification was void. The district court dismissed the complaint. The Supreme Court affirmed, holding that the WDOC was not required to file the inmate classification policy at issue with the Secretary of State's office, and therefore, Plaintiff failed to state a claim upon which relief can be granted. View "Bird v. Lampert" on Justia Law