Justia Wyoming Supreme Court Opinion Summaries

The case involves a divorce between Guy Morrison, III (Husband) and Tami Hinson-Morrison (Wife), who married in 2007. Before the marriage, they signed a premarital agreement stating that each party would retain their individual property, any property acquired from the proceeds or appreciation of their premarital property, and any property acquired by gift or inheritance. During the marriage, Husband formed three oil and gas companies and made various financial contributions to Wife's businesses and properties. Wife filed for divorce in 2022, leading to disputes over the interpretation and application of the premarital agreement and the equitable distribution of assets and debts.The District Court of Campbell County found the premarital agreement clear and unambiguous, except for its silence on commingling of funds. The court ruled that Husband's financial contributions to Wife's properties were spousal gifts and did not warrant compensation. The court divided the remaining marital assets and debts equitably, awarding Husband his businesses and other assets, while Wife retained her businesses and the marital home. The court also ordered the parties to file joint tax returns for 2021 and 2022 and bear their respective tax obligations proportionally.The Supreme Court of Wyoming affirmed the district court's decision. It held that the premarital agreement was clear and enforceable, and the district court correctly interpreted it without adding a commingling provision. The court also found no abuse of discretion in the equitable distribution of assets and debts, noting that the division left both parties in a comfortable financial position. The court declined to award Wife attorney fees, as the fee-shifting provision in the premarital agreement did not apply to the divorce proceedings. View "Morrison v. Hinson-Morrison" on Justia Law

High Plains Power, a cooperatively owned utility in central Wyoming, proposed a tariff revision to the Wyoming Public Service Commission (PSC) in August 2022. The revision aimed to change the compensation rate for customer-generators—members who generate electricity through small net metering systems—from a retail rate credit to an avoided cost rate, which is lower. Powder River Basin Resource Council and Wyoming Outdoor Council opposed this change, arguing it would unfairly reduce compensation for customer-generators.The PSC held a hearing in May 2023, where both parties presented evidence and testimony. The PSC approved the tariff revision on a two-to-one vote, with Chairman Throne dissenting. The appellants then petitioned the district court for review, which certified the case to the Wyoming Supreme Court.The Wyoming Supreme Court reviewed the case de novo and found that the PSC misinterpreted the relevant statute and failed to perform its ratemaking function. The court held that the PSC erred in presuming that the avoided cost rate was a just and reasonable rate for monthly compensation under Wyoming Statute § 37-16-103(a)(iii). The court emphasized that the statute does not specify the value of monthly credits or compensation, leaving it to the PSC to determine through its ratemaking process. The court concluded that the PSC did not evaluate the evidence or consider whether the proposed change served the public interest. Consequently, the Wyoming Supreme Court reversed the PSC's decision. View "Powder River Basin Resource Council v. Wyoming Public Service Commission" on Justia Law

Jarrett Gage Vargas was convicted of aggravated child abuse after his three-month-old foster child, RW, suffered severe injuries while in his care. On October 15, 2021, RW began seizing, prompting Vargas to call 911. Medical examinations revealed both acute and chronic subdural hematomas, a brain contusion, and retinal hemorrhages. Vargas admitted to handling RW roughly and bouncing him aggressively. The State charged Vargas with aggravated child abuse, arguing that RW’s injuries were caused by nonaccidental trauma.The District Court of Natrona County presided over the trial. The State presented medical experts who testified that RW’s injuries were consistent with abusive head trauma. Vargas countered with his own medical expert, who suggested that RW’s injuries could have been caused by a preexisting condition called external hydrocephalus, which could lead to subdural hematomas from benign activities. The jury found Vargas guilty of aggravated child abuse, and he was sentenced to 10-15 years in prison. Vargas filed a direct appeal and a motion for a new trial, claiming ineffective assistance of counsel. The district court denied the motion, and Vargas appealed that denial as well. The appeals were consolidated, but Vargas did not pursue the ineffective assistance claim further.The Wyoming Supreme Court reviewed the case, focusing on whether the district court erred in rejecting Vargas’ proposed theory of defense jury instruction. Vargas argued that the jury should have been instructed that if RW’s injuries could be explained by a preexisting medical condition, the State had not met its burden of proof. The Supreme Court held that Vargas’ proposed instruction was not a proper theory of defense, as it essentially argued a failure of proof rather than presenting a recognized legal defense. The court affirmed the district court’s decision, concluding that the jury was adequately instructed on the State’s burden of proof and that Vargas was able to present his arguments during the trial. View "Vargas v. State" on Justia Law

Rickey Dean Keefe was sentenced to three to six years in prison in 2020 for possession of methamphetamine with intent to deliver. While on parole in 2022, he was arrested and pled guilty to two new felony drug charges. In 2023, the district court sentenced him to seven to ten years in prison for the 2022 convictions but did not specify if the sentence would run consecutively or concurrently with the 2020 sentence. The Wyoming Board of Parole revoked his parole and treated the 2023 sentence as consecutive. Keefe filed a motion to correct the allegedly illegal sentence, which the district court denied.The District Court of Campbell County initially sentenced Keefe to five to seven years in prison in 2016, suspended in favor of probation. After multiple probation violations, the court imposed the 2020 sentence. In 2022, Keefe was arrested again and pled guilty to new charges. The district court merged the two counts for sentencing and imposed a single sentence of seven to ten years in 2023. Keefe's motion to correct the sentence argued that the sentences should run concurrently, but the district court denied the motion, citing precedent that sentences are presumed consecutive when the court is silent on the matter.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision. The court held that the district court did not abuse its discretion in denying Keefe’s motion. The court clarified that under Wyoming law, a sentence is presumed to be consecutive when the sentencing court is silent on whether it is concurrent or consecutive. The district court's subsequent order confirmed that the sentences should run consecutively. The court also rejected Keefe's argument that the State should be bound by its incorrect statement that sentences are presumed concurrent, noting that courts are not bound by parties’ admissions of law.The Wyoming Supreme Court affirmed the district court's decision, holding that Keefe's sentence was not illegal. View "Keefe v. The State of Wyoming" on Justia Law

Darren J. Gray suffered a heart attack while working on a road construction project and applied for workers' compensation benefits. The Wyoming Workers’ Safety and Compensation Division denied his request. After a contested case hearing, the Office of Administrative Hearings also denied the request, and the district court affirmed that decision. Mr. Gray appealed, arguing that his work exertion was unusual or abnormal under Wyoming law.The Office of Administrative Hearings found that Mr. Gray did not meet his burden of proof under Wyo. Stat. Ann. § 27-14-603(b)(ii) to show that his work exertion was unusual or abnormal for his employment. The Hearing Examiner determined that the tasks Mr. Gray performed on the day of his heart attack, including lifting and slamming metal pipes, were consistent with the job duties of similarly-situated employees. The district court affirmed this decision, agreeing that Mr. Gray's exertion was not clearly unusual or abnormal for his type of employment.The Wyoming Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the Hearing Examiner's conclusion was supported by substantial evidence, including job descriptions and testimony from Mr. Gray's supervisor. The court found that the tasks Mr. Gray performed were within the normal scope of his employment duties. The court also noted that the independent medical examiner's testimony did not establish that the exertion was unusual. Therefore, the court concluded that Mr. Gray did not meet the statutory requirements for workers' compensation benefits for his heart attack. View "Gray v. State, Ex Rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

In 2014, a woman and her two children from a previous relationship moved in with a man. They had a child together in 2018 and married in 2019. The man ran a trucking business, and the woman assisted with bookkeeping. She also worked briefly at a mental health facility and later as a secretary at a hospital. The couple separated in March 2022, and the woman filed for divorce shortly thereafter.The District Court of Weston County entered a stipulated decree of divorce in January 2023, settling child custody, visitation, and child support. However, the division of marital property was disputed. A bench trial was held in April, and the court issued its final order in November, dividing the marital property. The court considered the equitable value of the marital home, rental property, livestock, personal vehicles, personal property, and debts. The man was assigned the marital home, while the woman received her retirement funds and an equalization payment from the man.The man appealed to the Supreme Court of Wyoming, arguing that the district court abused its discretion in dividing the marital property. He contended that the court failed to allocate a portion of an IRS debt to the woman and improperly valued his trucking business. The Supreme Court reviewed the district court’s findings for an abuse of discretion and found no clear error. The court noted that the district court had appropriately considered the statutory factors under Wyo. Stat. Ann. § 20-2-114(a) and had made a just and equitable division of the property.The Supreme Court of Wyoming affirmed the district court’s decision, concluding that the property division was not so unfair and inequitable that reasonable people could not abide by it. The court also found that the district court had reasonably considered each of the statutory factors and that its ruling did not shock the conscience. View "Regan v. Regan" on Justia Law

Megan Vassilopoulos (Mother) and Kyle Vassilopoulos (Father) were granted a divorce by the District Court of Fremont County. The court awarded Father primary physical custody and decision-making authority over their minor child, LJV, and deviated the presumptive child support amount to zero. The court also divided the marital property, awarding Mother the marital home and other assets, while Father retained his businesses and other personal property. Mother appealed the custody, child support, and property division decisions.The District Court of Fremont County initially issued a temporary custody order, granting Mother primary physical custody and Father visitation rights. After a three-day bench trial, the court awarded joint legal custody, with Father having primary physical custody and decision-making authority. The court also deviated the presumptive child support amount to zero, citing the number of days LJV was with Mother and her provision of health insurance. In a subsequent two-day bench trial, the court divided the marital property, awarding Mother the marital home and other assets, while Father retained his businesses and other personal property.The Supreme Court of Wyoming reviewed the case. It affirmed the district court’s custody and property division orders, finding no abuse of discretion. The court held that the district court adequately considered the child’s best interests and the statutory factors for property division. However, the Supreme Court found that the district court abused its discretion by deviating from the presumptive child support amount without fully explaining its reasons. The court reversed and remanded the child support order for further findings based on the evidence in the record. View "Vassilopoulos v. Vassilopoulos" on Justia Law

In two separate cases, employees Terry J. Leal and Dustin Kopp sought workers' compensation benefits for injuries they claimed were work-related. Ms. Leal's claim involved a right shoulder injury, while Mr. Kopp's claim involved an abdominal hernia. Both claims were initially denied by the Wyoming Department of Workforce Services, Workers’ Compensation Division, which concluded that the injuries were not caused by their work activities. The employees contested these decisions, leading to hearings before the Office of Administrative Hearings (OAH).In both cases, the OAH appointed attorneys to represent the employees. These attorneys hired medical experts to testify on the causation of the injuries. Ms. Leal's attorney hired Dr. Gregory Reichhardt, and Mr. Kopp's attorney hired Dr. Douglas Adler. The OAH found in favor of the employees, awarding them workers' compensation benefits. However, when the attorneys sought reimbursement for the medical expert fees, the OAH denied these requests, citing a lack of statutory authority under the Wyoming Worker’s Compensation Act to order such reimbursements.The employees appealed to the District Court of Laramie County, which certified the cases to the Wyoming Supreme Court. The Wyoming Supreme Court reviewed whether the OAH had the authority to order reimbursement of medical expert fees. The Court concluded that the OAH does have such authority. It reasoned that the Wyoming Worker’s Compensation Act, when read as a whole, provides for the payment of costs, including expert witness fees, to ensure the quick and efficient delivery of benefits to injured workers at a reasonable cost to employers. The Court found that the OAH's decision to deny reimbursement was not in accordance with the law and reversed the OAH's decision. View "Leal v. State of Wyoming, ex rel. Department of Workforce Services" on Justia Law

Anne G. McNair experienced a perforated esophagus and infection following cervical fusion surgery performed by Dr. Joshua D. Beck at North Lincoln County Hospital District, d/b/a Star Valley Health. Dr. Beck, employed by Orthopaedics of Jackson Hole, P.C., d/b/a Teton Orthopaedics, continued to treat her post-surgery. McNair filed a complaint against Dr. Beck, Teton, and Star Valley, alleging medical malpractice, negligence, and vicarious liability. The district court dismissed her complaint, citing the statute of limitations, and denied her motion to amend the complaint, deeming it futile.The District Court of Lincoln County granted the defendants' motions to dismiss, concluding that McNair's claims were filed beyond the two-year statute of limitations for medical malpractice actions. The court determined that the continuous treatment rule did not apply, as McNair's injury stemmed from a single act of negligence during the surgery on December 30, 2020. Consequently, the court found that the statute of limitations began on December 31, 2020, the date McNair was discharged from the hospital, making her April 2023 filings untimely. The court also denied McNair's motion to amend her complaint, asserting that any amendment would be futile.The Supreme Court of Wyoming reviewed the case and found that the district court erred in its application of the continuous treatment rule. The Supreme Court held that the continuous treatment rule applies when a medical provider has provided ongoing care for the same or related complaints. The court noted that McNair's complaint alleged continuous treatment by Dr. Beck and Teton into early 2021, which could extend the statute of limitations. The court also found that the district court abused its discretion in denying McNair's motion to amend her complaint, as the proposed amendments did not show on their face that the claims were untimely. The Supreme Court reversed the district court's decision and remanded the case for further proceedings. View "McNair v. Beck" on Justia Law

Amy Romero was arrested for driving while under the influence of alcohol (DWUI) after being found stuck in a snowbank. Officer George Phillips of the Rawlins Police Department noticed the vehicle and, upon investigation, detected a strong odor of alcohol from Ms. Romero. During the interaction, Ms. Romero admitted to driving the vehicle and exhibited signs of intoxication. Officer Phillips placed her in the back of his patrol car to deescalate a potentially violent situation with her husband, Joseph Romero, who was also present and behaving aggressively.The Office of Administrative Hearings (OAH) upheld the suspension of Ms. Romero’s driver’s license, concluding that Officer Phillips had reasonable suspicion to detain her for a DWUI investigation. The OAH found that the officer’s actions, including placing Ms. Romero in the patrol car and transporting her to a dry environment for field sobriety tests, were justified based on the totality of the circumstances, including the strong odor of alcohol, her admission of driving, and the need to manage her husband’s aggressive behavior.The Wyoming Supreme Court reviewed the case and affirmed the OAH’s decision. The Court held that Officer Phillips’ detention of Ms. Romero in the back of the patrol car did not constitute an unlawful arrest but was a reasonable investigative detention supported by substantial evidence. The Court found that the officer’s actions were necessary to ensure safety and were within the scope of a lawful investigative detention. The Court concluded that the OAH’s findings were supported by substantial evidence and that the detention was in accordance with constitutional protections. The decision to uphold the suspension of Ms. Romero’s driver’s license was affirmed. View "Romero v. State of Wyoming Ex Rel., Wyoming Department of Transportation" on Justia Law