Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the district court modifying the child support Father paid to Mother for the benefit of the parties' three minor children, 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 not holding an evidentiary hearing before calculating child support; (2) the district court did not abuse its discretion when it calculated Father's income, when it did not allow a downward deviation from Father's presumptive child support, and when it did not use a shared responsibility calculation; and (3) Mother was not entitled to costs and reasonable attorney fees. View "Marquis v. Marquis" on Justia Law

The Supreme Court affirmed the judgment of the district court finding that Plaintiff's complaint against Defendant, a surgeon, alleging that he negligently treated Plaintiff's spinal condition, was barred by the statute of limitations, holding that the district court correctly found that Plaintiff's complaint was untimely filed.In her complaint, Plaintiff alleged that Defendant did not meet the applicable standard of care in his performances of surgeries on her and in her after care. Defendant moved for summary judgment, asserting that the complaint was barred by the applicable statute of limitations, Wyo. Stat. Ann. 1-3-107. The district court granted the motion. The Supreme Court affirmed, holding that the district court did not err in finding that the statute of limitations expired four days before Plaintiff's complaint was filed. View "Candelaria v. Karandikar" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony theft, holding that Defendant was not denied his constitutional right to a speedy trial.On October 2, 2017, Defendant was arrested for the theft of a vehicle. While he was detained in Natrona County, Fremont County filed charges against him for the theft of another vehicle. Fremont County filed an information but did not pursue further prosecution on the charges for 481 days. During that time, Defendant was convicted in Natrona County and began serving a sentence. On September 26, 2019, Defendant filed a motion to dismiss the Fremont County charges for lack of a speedy trial. The district court denied the motion. Defendant then entered into a conditional guilty plea agreement. On appeal, Defendant argued that he was denied his constitutional right to a speedy trial. The Supreme Court affirmed, holding that Defendant's constitutional right to a speedy trial was not violated. View "Crebs v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of attempted aggravated robbery, holding that the district court did not commit judicial misconduct or deprive Defendant of a fair trial by commenting on the foundation for admission of the gun used in the robbery and did not abuse its discretion by denying Defendant's motion for a mistrial.On appeal, Defendant argued that the district court committed misconduct by explaining to the State how to lay the foundation for admission into evidence of the gun and erred by denying his motion for a mistrial after the State elicited an answer from a witness in violation of an order in limine. The Supreme Court affirmed, holding (1) the district court did not deprive Defendant of a fair trial; and (2) although the witness's testimony violated the order in limine the district court properly concluded that the error was not so prejudicial that it denied Defendant a fair trial. View "Langley v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiffs' complaint under Wyo. R. Civ. P. 12(b)(6) and (c), holding that the district court did not err.Plaintiffs sued Defendants asserting claims for defamation per se, tortious interference with a prospective economic advantage and business expectancy, and false light invasion of privacy. The district court dismissed all claims. The Supreme Court affirmed, holding (1) Plaintiffs did not state claims for defamation per se; (2) Plaintiffs could not recast their second cause of action as a claim for prima facie tort; and (3) Plaintiffs did not state a claim for false light invasion of privacy. View "Bextel v. Fork Road LLC" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of aggravated felony child abuse, holding that the district court did not err in admitting Wyo. R. Evid. 404(b) evidence from misconduct that was originally charged but dismissed by the circuit court.Defendant was convicted of inflicting injuries on a minor child, PS on November 2 and November 3, 2018. On appeal, Defendant argued that the district court erred in admitting evidence related to an incident on September 10, 2018, in which Defendant admitted that he threw a bottle at PS and bruised her head. Specifically, Defendant argued that it was improper to admit the evidence under Wyo. R. Evid. 404(b) because the evidence related to a charge dismissed at the preliminary hearing. The Supreme Court disagreed, holding that the district court did not err in admitting the evidence surrounding the September 10, 2018 incident. View "Putnam v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of possession of methamphetamine, possession with intent to deliver methamphetamine, and conspiracy to deliver methamphetamine, holding that the district court did not err in denying Defendant's motion to suppress.After Wyoming Division of Criminal Investigation agents gathered information that Defendant was selling methamphetamine they installed a GPS tracking device on his truck. Wyoming Highway Patrol Troopers initiated a traffic stop of Defendant based on a crack in the front windshield of his truck. After a search, drugs and drug paraphernalia were discovered. Defendant moved to suppress, which the trial court denied. The Supreme Court affirmed, holding that the Troopers had reasonable suspicion to stop the truck for driving with a crack within the front windshield. View "Simmons v. State" on Justia Law

The Supreme Court reversed the judgment of the district court denying Steven Mitchell's motion for a sentence reduction as untimely, holding that the district court erred in denying Mitchell's motion as untimely.Defendant pled no contest to one count of felony interference with custody. The district court sentenced Defendant to three and one-half years in prison. Defendant later filed a pro se Wyo. R. Crim. P. 35(b) motion for reduction of his sentence. The district court issued an order denying the motion as untimely. The Supreme Court reversed and remanded the case to the district court for a ruling on the merits, holding that the district court erred in denying the motion as untimely and that the error was not harmless. View "Mitchell v. State" on Justia Law

The Supreme Court affirmed the district court's denial of a motion to set aside default judgment against it after it failed to answer a writ of garnishment, holding that, despite certain procedural infirmities, the district court did not err in denying the motion to set aside default judgment.After Monty Elliott obtained a judgment his efforts to collect led to a writ of garnishment of Sonny Pilcher's earnings from Rack's Gentlemen's Club, a business operated by CC Cowboy's Inc. The district court entered default judgment against CC Cowboys. Pilcher filed a motion to vacate default judgment, which the district court denied. The Supreme Court affirmed, holding that CC Cowboys waived its objection to personal jurisdiction by appearing in the proceeding without making that objection. View "Pilcher v. Elliott" on Justia Law

The Supreme Court remanded this case to the district court with instructions to determine whether excusable neglect extended Plaintiff's time to file the petition for review of the decision of the Office of Administrative Hearings (OAH) concluding that Plaintiff's infection was not compensable, holding that the record did not reveal whether the district court considered the question of excusable neglect.Plaintiff scraped his knuckle on a locker as he was getting ready to leave a trona mine, where he worked. The scrape developed necrotizing fasciitis, causing serious injuries. The Department of Workforce Services, Workers' Compensation Division, deemed Plaintiff's injury compensable. The OAH served an order concluding that Plaintiff's injuries were not compensable. The district court reversed, concluding that Plaintiff's infection was compensable. Plaintiff's employer appealed, arguing that the district court lacked jurisdiction because the petition for judicial review was untimely filed. The Supreme Court remanded the case for the limited purpose of determining whether excusable neglect extended the time for filing a petition for review. View "Tata Chemicals Soda Ash Partners, Ltd v. Vinson" on Justia Law