Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court granting Defendant's motion to compel arbitration under the "voluntary agreement for arbitration" Rick Miller signed on behalf of his mother, Julia Miller, after she was admitted to Life Care Center of Casper (LCCC), holding that Rick lacked authority to execute the agreement.After Julia died allegedly from injuries sustained during a series of mishaps at LCCC Rick filed this complaint stating claims of negligence and premises liability against Defendant. Defendant filed a motion to compel arbitration. The court granted the motion. The Supreme Court reversed, holding (1) Julia's durable power of attorney for health care did not grant Rick express actual authority to sign the arbitration agreement; (2) Julia did not hold Rick out as having apparent authority to sign the agreement; and (3) Rick was not authorized to execute the arbitration agreement as Julia's "surrogate" under the Wyoming Health Care Decisions Act, Wyo. Stat. Ann. 35-22-401 through 416. View "Miller v. Life Care Centers of America, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction of conspiracy to deliver a controlled substance and delivery of a controlled substance, holding that the State's introduced of unnoticed Wyo. R. Evid. 404(b) evidence and irrelevant evidence about Defendant's citizenship did not deny him his right to a fair trial.Specifically, the Supreme Court held (1) even if the challenged evidence constituted Rule 404(b) evidence requiring the State to provide pretrial notice, the district court's admission of the evidence was not prejudicial; and (2) the admission of the irrelevant evidence concerning Defendant's citizenship did not demonstrate material prejudice, and Defendant did not identify anything to suggest that the verdict would have been different had the prosecutor not asked about Defendant's citizenship. View "Gutierrez v. State" on Justia Law

The Supreme Court remanded this case to the district court for dismissal of all but its order invalidating Rule CKA, a rule adopted by the Unita County School District Number One permitting school personnel to carry firearms on school property, holding that the district court's order invalidating Rule CKA rendered all other issues moot.Plaintiffs brought this action alleging that Rule CKA violated the Wyoming Constitution, did not comply with the enabling statute, and was not adopted in compliance with the Wyoming Administrative Procedure Act. The district court granted summary judgment on Plaintiffs' count alleging violation of the enabling statute and dismissed or granted summary judgment for the school district on the remaining three counts. Plaintiffs appealed. The Supreme Court remanded the case, holding that there were no live issues remaining to be litigated when the district court entered its order invalidating Rule CKA, and therefore, the court should have dismissed the other claims. View "Beppler v. Uinta County School District Number One" on Justia Law

The Supreme Court affirmed Defendant's conviction of two controlled substance charges, holding that the district court did not err in denying Defendant's motion to suppress evidence found during a search of the rental van he was driving.Defendant was charged with four drug-related felonies. Defendant moved to suppress evidence found in the rental van that he was driving, arguing that law enforcement violated his Fourth Amendment rights against unreasonable search and seizure when they detained him for the purpose of having a dog unit arrive of scene. The trial court denied the motion. The Supreme Court affirmed, holding that the district court did not err when it denied Defendant's motion to suppress because law enforcement did not violate Defendant's constitutional rights under the Fourth Amendment. View "Pryce v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of aggravated homicide by a vehicle under Wyo. Stat. Ann. 6-2-106(b)(ii), holding that the district court erred in denying Defendant's motion for judgment of acquittal because the evidence presented by the State was insufficient to show that she acted recklessly.During a trial, the State argued that Defendant acted in a reckless manner by consciously disregarding fatigue and that Defendant's conduct was the proximate cause of the death of another person. Defendant moved for a judgment of acquittal, arguing that the evidence was too uncertain to show that she acted recklessly. The district court denied the motion, and the jury found Defendant guilty. The Supreme Court reversed, holding that the State's evidence, taken as true, was insufficient for the jury to conclude beyond a reasonable doubt that Defendant acted recklessly. View "Hightower v. State" on Justia Law

The Supreme Court summarily affirmed the judgments of the district court in favor of Plaintiff on his two complaints seeking to be declared the sole owner of certain real properties and to invalidate certain documents in the properties' chains of title, holding that Defendant's pro se briefs failed to comply with the Wyoming Rules of Appellate Procedure.In each case, Plaintiff filed a motion for summary judgment, and Defendant did not respond to the motions. The district court granted Plaintiff's motions and entered judgments declaring him to be the sole owner of the properties and invalidating the documents at issue. Defendant appealed, raising seven issues in his pro se briefs. The Supreme Court summarily affirmed the district court's judgments, holding that Defendant's pro se briefs did not provide any cogent argument and otherwise failed to comply with the rules of appellate procedure. View "Corrigan v. Vig" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of sexual abuse of a minor in the second degree, holding that the admission of Wyo. R. Evid. 404(b) evidence was not prejudicial error.On appeal, Defendant argued that the State introduced improper Rule 404(b) evidence by eliciting testimony from the victim about an earlier incident when she and Defendant were wrestling. The Supreme Court affirmed, holding (1) the testimony regarding the wrestling incident implicated Rule 404(b); but (2) Defendant was not prejudiced because there was no reasonable probability that the verdict would have been more favorable had the wrestling incident evidence not been admitted. View "Cox v. State" on Justia Law

In this breach of contract action, the Supreme Court affirmed the judgment of the district court awarding APMTG over $35 million in damages and interest, holding that the district court did not err.Denbury Onshore, LLC agreed to deliver certain amounts of helium to APTMG each year. When Denbury failed to deliver the required amounts, it claimed its nonperformance was excused by two force majeure events. The district court concluded that Denbury had failed to show its non-performance was excluded by a force majeure event except for a period of thirty-six days. The Supreme Court affirmed, holding that the district court did not err in (1) deciding Denbury's request to terminate the parties' agreement under the doctrines of frustration of purpose and/or impossibility of performance; (2) deciding that Denbury had failed to prove its nonperformance between April 23, 2013 and December 30, 2013 was excused by a force majeure event; and (3) deciding that Denbury had failed to prove its nonperformance after mid-August of 2014 was excused by a force majeure event. View "Denbury Onshore, LLC v. APMTG Helium LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court entered on the jury's verdict finding Defendant not negligent, holding that there was sufficient evidence to support the jury verdict.Following a car collision, Plaintiff sued Defendant for negligence. During trial, Plaintiff moved for judgment as a matter of law on the issue of Defendant's negligence. The district court reserved its ruling on the motion and gave the case to the jury. The jury found Defendant not negligent, and the court entered judgment on the verdict. The Supreme Court affirmed, holding (1) the court acted appropriately in sending the issue of Defendant's negligence to the jury; and (2) the jury could reasonably conclude from the evidence that Defendant failed to meet his burden to establish that Defendant breached his duty of ordinary care under the circumstances. View "Wageman v. Harrell" on Justia Law

The Supreme Court affirmed Defendant's convictions, holding that Defendant failed to prove that the district court abused its discretion in its evidentiary rulings and challenged jury instructions and failed to prove the evidence was insufficient to convict him.Specifically, the Supreme Court held (1) the district court did not abuse its discretion when it allowed the State to play a recorded phone call between Defendant and his co-defendant; (2) the district court did not abuse its discretion when it refused to give Defendant's proposed modification to the pattern jury instruction on possession; and (3) the evidence was sufficient to support Defendant's convictions. View "Mitchell v. State" on Justia Law