Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court setting aside an investigative subpoena served by the Consumer Protection Unit of the Wyoming Office of Attorney General, holding that there was no error or abuse of discretion.WyoLaw, LLC filed this petition to set aside the Attorney General's subpoena, claiming that it was not subject to the Attorney General's investigative authority, that the Attorney General lacked probable cause to support its subpoena, and that the documents were protected by the work product doctrine and the attorney client privilege. The district court denied the request to modify or set aside the subpoena and ordered WyoLaw to produce the documents. The Supreme Court affirmed, holding that the district court did not abuse its discretion. View "WyoLaw, LLC v. State, Office of the Attorney General, Consumer Protection Unit" on Justia Law

In this eminent domain dispute, the Supreme Court reversed the first order of the district court allowing EME Wyoming, LLC access to approximately 52,000 acres of land located primarily in Goshen County and affirmed the second order permanently barring EME from using survey information it collected to file permits to drill (APD) with the Wyoming Oil and Gas Conservation Commission (WOGCC), holding that the district court erred in part.EME sought access to land owned by four limited liability companies (collectively, the BRW Group) for the purpose of gathering data to evaluate the property's suitability for condemnation. The BRW Group denied EME's request, believing that EME sought access to the lands solely to collect data with which to file APDs, which is not a proper purpose under the Wyoming Eminent Domain Act. The district court allowed EME to access the property to survey and gather data but restricted it from using the survey information to file APDs. The Supreme Court reversed in part, holding (1) EME should not have been permitted access to the property because it did not make the required showing for access to the BRW Group's property; and (2) therefore, the data EME collected to file APDs was not lawfully in EME's possession, and EME could not use the data for any purpose. View "BRW East, LLC v. EME Wyoming, LLC" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence obtained at the end of a traffic stop, holding that the traffic stop was unlawfully extended after its initial purpose had been resolved.Defendant entered a conditional plea to methamphetamine possession and child endangerment. Defendant appealed, arguing that the district court erred in denying his motion to suppress evidence obtained at the end of the traffic stop because the stop was unlawfully extended before a drug dog alerted. The Supreme Court agreed, holding (1) Defendant did not waive his argument that the stop was unlawfully extended; and (2) Defendant's Fourth Amendment rights were violated because the law enforcement officer unlawfully extended the duration of the traffic stop after he completed the citation. View "Mahaffy v. State" on Justia Law

The Supreme Court answered in the affirmative a question certified to it by the United States Court of Appeals asking whether an insurance policy is "issued for delivery" or "delivered" under Wyo. Stat. Ann. 26-15-101(a)(ii) even if not copy was conveyed to Wyoming and the police listed only an out-of-state address for the insured.Specifically, the Supreme Court held (1) for purposes of Wyo. Stat. Ann. 26-15-101(a)(ii), an insurance contract is "delivered" in Wyoming if it is actually or constructively delivered in Wyoming, and an insurance contract is "issued for delivery" where the policy was intended to be delivered; and (2) absent an insurance contract unambiguously stating otherwise, if the location of the insured and the location of the risk to be insured are both in Wyoming, an insurance policy is intended to be delivered and is issued for delivery in Wyoming. View "Sinclair Wyoming Refining Co. v. Infrassure, Ltd" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Father's petition to modify custody and support of the parties' children, holding that there was no due process violation or abuse of discretion.Two months after the district court entered its order granting primary physical custody of the parties' children to Mother and ordering Father to pay child support Father filed his petition to modify custody and support. Father alleged that a material change in circumstances had arisen since the previous custody and support order. After a trial, the district court denied the motion, concluding that there had been on material change in circumstances. The Supreme Court affirmed, holding that the district court (1) did not violate Father's due process rights by denying his request to call the guardian ad litem to testify as to her bias; and (2) did not abuse its discretion by refusing to deduct mortgage interest to determine Father's income for purposes of calculating child support. View "Lemus v. Martinez" on Justia Law

The Supreme Court affirmed Defendant's conviction of attempted second-degree murder, holding that the overwhelming evidence of guilt precluded a conclusion that any alleged errors were prejudicial.On appeal, Defendant argued that his counsel provided ineffective assistance and that the prosecutor committed prejudicial misconduct. The Supreme Court affirmed, holding that the district court did not err in denying Defendant's motion for a new trial due to ineffective assistance of counsel and that prosecutorial misconduct did not deny Defendant a fair trial. Specifically, the Court held that Defendant failed to demonstrate prejudice, which was dispositive of both of his claims. View "Leners v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Father's Wyo. R. Crim. P. 60(b)(4) motion seeking relief from the district court's child custody and support order, holding that Rule 60(b)(4) could not relieve Father from the district court's child support order.As part of the parties' divorce decree, the district court ordered Father to pay the $50 minimum support obligation prescribed by Wyo. Stat. Ann. 20-2304(b) to Mother. Father later brought this action moving from relief from the child custody and support order, arguing that the child support order was void because Wyo. section 20-2304(b) is unconstitutional. The motion was deemed denied. The Supreme Court affirmed, holding that because the child support order would be voidable, not void, Rule 60(b)(4) could not relieve Father from the child support order. View "Carroll v. Gibson" on Justia Law

The Supreme Court affirmed the judgment of the district court terminating Mother's parental rights to Child, holding that the district court did not err or abuse its discretion.The Wyoming Department of Family Services filed a petition to terminate Mother's parental rights to Child, but Mother failed timely to respond. The clerk of the district court proceeded to enter default against Mother. On appeal, Mother argued that the district court violated her due process rights by holding the evidentiary default hearing by video conference and by not giving her a meaningful chance to be heard regarding Child's best interests. The Supreme Court affirmed, holding that Mother's due process rights were not violated when the district court held the default hearing by video conference or when it limited Mother's participation at the hearing. View "Herden v. State, ex rel. Department of Family Services" on Justia Law

The Supreme Court affirmed the order of the district court granting Defendants' motion to dismiss this legal malpractice complaint and to compel arbitration based on the arbitration provision in the parties' engagement agreement, holding that the district court erred when it failed to stay the malpractice action.On appeal, Plaintiff argued that the arbitration provision and the engagement agreement were unenforceable and that the district court erred when it failed to stay the malpractice action as required by the Wyoming and Utah Uniform Arbitration Acts. The Supreme Court agreed, holding (1) the district court properly limited the scope of its arbitrability ruling to address only the enforceability of the arbitration provision; and (2) the district court erred when it dismissed the legal malpractice action upon ordering arbitration. View "Inman v. Grimmer" on Justia Law

The Supreme Court affirmed Defendant's sentence imposed in connection with his plea of guilty to escape, holding that the district court properly found that Defendant was not entitled to any credit in this case.Defendant pleaded guilty to escape, and the district court imposed a twenty to forty-month sentence to run consecutive to his underlying sentence. The district court ordered the 111 days Defendant spent in custody prior to his sentence on the escape charge to be credited to his underlying sentence for property destruction. On appeal, Defendant argued that his sentence was illegal because he had not received credit for the 111 days. The Supreme Court affirmed, holding (1) the district court properly credited the time Defendant served after his arrest in the escape case to the underlying property destruction case; and (2) a motion to correct an illegal sentence was not the proper method to challenge the Department of Corrections' administration of a sentence. View "Newnham v. State" on Justia Law