Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court dismissed this appeal from the decision of the district court reversing the decision of the director of the Wyoming Department of Environmental Quality (WDEQ) and the Environmental Quality Council (EQC) denying Brook Mining Company's application for a permit to develop and operate a new surface coal mine, holding that the issues presented in this appeal were moot.The EQC concluded that the permit application was deficient and denied Brook Mining Company's application. The Director of the WDEQ then denied the permit. The district court reversed. While this appeal was pending, Brook Mining Company submitted a revised permit application. The Director issued a decision that approved the revised permit application. Also while the appeal was pending, the legislature changed the regulatory structure for the approval of new coal mine applications by removing the opportunity for an EQC contested case hearing prior to the Director's decision. The Supreme Court dismissed the appeal, holding that the issues in this appeal do not continue to present a justiciable controversy and have thus become moot. View "Fisher v. Wyoming Department of Environmental Quality" on Justia Law

The Supreme Court affirmed the decision of the district court using a judgment against Alexander Mantle to set off judgments Alexander and Majorie Mantle had against Ray and Gary Garland and failing to recognize the Mantles' right to the proceeds from a settlement of a third-party action against Karl Killmer and Killmer & Associates (collectively, Killmer), holding that the district court did not err.Specifically, the Supreme Court held (1) Ray and Gary were entitled to use the assigned portions of the judgment against Alexander to satisfy the judgments the Mantles had against them for fraudulent transfers; and (2) the district court did not have jurisdiction to the portion of the Killmer settlement funds not deposited with the district court. View "Mantle v. North Star Energy & Construction LLC" on Justia Law

The Supreme Court affirmed the decision of the district court granting Goshen County Fairgrounds summary judgment on its assertion of governmental immunity and dismissing Plaintiff's negligence action, holding that Plaintiff did not establish a genuine issue of material fact that would preclude summary judgment on the basis of the Fairgrounds' immunity.Plaintiff fell at an event held in one of the Goshen County Fairgrounds' buildings. Plaintiff filed a complaint against Goshen county, the State, and the Fairgrounds, alleging negligence. The district court granted summary judgment for the Fairgrounds. The Supreme Court affirmed, holding that disputed issues of material fact did not exist so as to preclude summary judgment on the question of whether the Fairgrounds and its employees were negligent in the operation or maintenance of the building. View "Varela v. Goshen County Fairgrounds" on Justia Law

The Supreme Court reversed the judgment of the district court granting Mother's Wyo. R. Civ. P. 59 motion to alter or amend the judgment requiring that the parties' child name not be changed after the court previously granted Father's motion to change the child's name, holding that the district court abused its discretion.Siobham Jerding (Mother) was married to someone else when she entered into a relationship with Terrance Brown (Father). Mother later gave birth to MFJ. The birth certificate listed Mother's husband as the child's father. Father filed a petition to establish paternity, custody, and visitation and to change MFJ's surname to Brown. The district court granted Father's motion to change MFJ's name to Brown. Thereafter, Mother filed her Rule 59 motion, arguing that the district court did not make a finding of good cause. The district court granted Motion's motion. The Supreme Court reversed, holding that none of the grounds for granting a Rule 59 motion were present in this case. View "Brown v. Jerding" on Justia Law

The Supreme Court affirmed the judgment of the district court sentencing Defendant, after a remand, to an aggregate sentence of twelve to fifty years for aggravated robbery, to be served consecutively to a previously imposed sentence for first-degree murder, holding that Defendant's aggregate sentence was constitutional.When Defendant was seventeen years old he and a friend robbed and murdered a hitchhiker. Defendant pled guilty to first degree murder, felony murder, and aggravated robbery. Defendant was convicted to life without parole, which the court later converted to life with the possibility of parole after twenty-five years for murder plus twenty to fifty years for aggravated robbery. Defendant later filed a motion to correct an illegal sentence, arguing that his new aggregate sentence remained a de facto life sentence. The trial court denied the motion, but the Supreme Court remanded. On remand, the trial court resentenced Defendant to twelve to fifty years for aggravated robbery, to be served consecutively to the previously imposed sentence for murder. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it sentenced Defendant for aggravated robbery. View "Davis v. State" on Justia Law

The Supreme Court reversed the judgment of the district court terminating Appellant's parental rights, holding that the district court violated Appellant's due process rights when it determined the best interests of the child without first conducting an evidentiary hearing.The district court found that the Department of Family Services established statutory grounds for termination by clear and convincing evidence. On appeal, Appellant argued that he was not given an opportunity to be heard on the question of whether termination was in the child's best interests. The Supreme Court held (1) neither the termination statutes nor Wyoming case law require a separate hearing to determine the best interests of the child; but (2) Appellant's due process rights were violated when he was deprived of the opportunity to be heard on the question of best interests. View "Niland v. State, ex rel. Department of Family Services" on Justia Law

The Supreme Court affirmed in part the judgment of the district court finding Bradley Jenkins in contempt for failing to follow the terms of its stipulated divorce decree and remanded for the district court to clarify its order as it pertained to refinancing the marital home, holding that it was unclear whether the court intended to impose the refinancing obligation on Bradley.The divorce decree awarded the marital home to Jonnie Jenkins and required her to refinance it and pay Bradley his share of the equity. Jonnie was unable to obtain refinancing because of numerous liens attached to the home. Jonnie asked the district court to hold Bradley in contempt for failing to comply with the divorce decree. The district court held both parties in contempt and ordered Bradley to release all judgment liens on the title to the marital home and assume the second mortgage. The Supreme Court remanded the case, holding (1) the district court did not err by requiring Bradley to make reasonable and consistent efforts to release the liens on the marital home; and (2) it was unclear which party was obligated to obtain refinancing for the marital home. View "Jenkins v. Jenkins" on Justia Law

The Supreme Court reversed the decision of the district court dismissing with prejudice Plaintiff's legal malpractice suit against the Office of the State Public Defender, the State Public Defender, and the individual public defenders who represented him in his criminal case, holding that exoneration is not a prerequisite for a malpractice action.In dismissing Plaintiff's action, the district court found that none of the exceptions to governmental immunity in the Wyoming Governmental Claims Act (WGCA) applied and that the exoneration rule made Plaintiff's claim premature. The Supreme Court reversed, holding (1) Plaintiff's malpractice claim did not fall within the WGCA's contract exception; (2) the issue of the Public Defenders' insurance coverage was not properly disposed of on a motion to dismiss; and (3) the exoneration rule did not bar Plaintiff's malpractice suit. View "Dockter v. Lozano" on Justia Law

The Supreme Court reversed the decision of the district court denying TE's petition to establish paternity of AE on the grounds that TE had not timely filed his petition and remanded for an order adjudicating TE as AE's father, holding that while the district court has discretion to determine the timeliness of a paternity petition before ordering testing, the statutes do not afford the district court discretion on the timeliness of a petition after ordering genetic testing.The Department of Family Services later took protective custody of AE and sought to terminate the rights of AE's parents. Mother and the presumed father voluntarily relinquished their parental rights to AE. TE, who was listed on the termination petition as the alleged father, filed a petition to establish paternity. Genetic testing was conducted and disclosed a 99.99 percent probability of paternity. After a trial, the district court found that TE's petition was not timely filed and denied the petition. The Supreme Court reversed, holding (1) the Department lacked standing to contest TE's petition to establish paternity; and (2) the district court lacked the discretion to adjudicate parentage after it was presented with court-ordered genetic testing results that complied with the statutes and indicated that TE was AE's biological father. View "TE v. State, Department of Family Services" on Justia Law

The Supreme Court dismissed Defendant's appeal from the district court's dismissal of his pro se "Petition for Exoneration Based on Factual Innocence," holding that Defendant did not properly invoke the Supreme Court's jurisdiction.Defendant was convicted of three counts of sexual abuse of a minor in the second degree and one count of sexual abuse of a minor in the third degree. Defendant later filed his petition for exoneration under Wyo. Stat. Ann. 7-12-401 through -407. The district court dismissed the petition without prejudice, determining that the petition was statutorily noncompliant. Defendant appealed. The Supreme Court dismissed the appeal, holding that the dismissal of Defendant's petition was not a final, appealable order, and therefore, this Court lacked jurisdiction over Defendant's appeal. View "Woods v. State" on Justia Law