Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court concluding that the Successor Trustee of The Phillip G. Jackson Family Revocable Trust lacked authority to sell real property held by the Trust for the care, maintenance and support of the surviving settlor, holding that the district court did not err as a matter of law.The Successor Trustee filed a complaint for declaratory judgment requesting a ruling that he could sell real property held by the Trust for the support of the surviving settlor, Phillip Jackson. The district court found that the Successor Trustee had no authority to eject Candyce Montoya, who had resided rent-free at the property for over forty years, from the property and to sell it for the benefit of Mr. Jackson during Montoya's life because the Trust granted Montoya a life interest in the property. The Supreme Court reversed, holding (1) Montoya's interest in the property will not vest until the death of the remaining settlor; and (2) therefore, the Successor Trustee may sell the property for the benefit of the remaining settlor in accordance with the terms of the Trust. View "Jackson v. Montoya" on Justia Law

The Supreme Court reversed in part the district court's final judgment incorporating the jury's special verdict in favor of the Goddards and rendering judgment in favor of Sand Creek Ranch Preservation Association, Inc. (SCRPA) and against Goddard Ranch on two of its claims for declaratory relief that were not included in the jury's verdict, holding that SCRPA and Johnson County Ranch Improvement #1 (JCRI) waived their arguments on appeal and that the district court erred in entering final judgment on SCRPA's claims for declaratory relief.Goddard Ranch, LLC purchased ranch lands in a subdivision where private home lots were surrounded by ranch land. The fence encroached upon easements belonging to the homeowners. JCRI and SCRPA, whose members were owners of the residential lots, sued Goddard Ranch and three individuals (collectively, the Goddards). The jury returned a special verdict for the Goddards. The final judgment incorporated the special verdict and rendered judgment in favor of SCRPA on two of its claims for declaratory relief that were not included in the jury's verdict. The Supreme Court held (1) the arguments SCRPA and JCRI on appeal were not reviewable; and (2) there was no justiciable controversy with respect to SCRPA's claims for declaratory relief concerning SCRPA's right to install signage and certain facilities within the easements. View "Johnson County Ranch Improvement #1, LLC v. Goddard" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing a corporation's (the Corporation) counterclaims after it was sued by two trusts (the Trusts), holding that the district court erred by dismissing the counterclaims.The Trusts sued the Corporation for payment of loans they made to the Corporation to finance its oil and gas service operations in Australia. The Corporation asserted affirmative defenses and counterclaims. The district court dismissed the counterclaims on the grounds that they unduly complicated the action. The jury ruled that the Trusts had breached the implied covenant of good faith and fair dealing and that the Corporation owed reduced damages to one of the trusts. The Supreme Court reversed, holding (1) the district court erred by dismissing the Corporation's counterclaims because Wyo. R. Civ. P. 13 does not authorize courts to dismiss permissible counterclaims simply because they would unduly complicate the action; and (2) on remand, the court must address a few problems with the jury instructions. View "Gas Sensing Technology Corp. v. New Horizon Ventures Pty Ltd" on Justia Law

The Supreme Court affirmed the decision of the district court denying Clint Webb's motion to modify a child support order, holding that the district court did not abuse its discretion.Pursuant to a divorce decree, the district court ordered Clint to pay Julia Webb $50 a month in child support. Clint did not appeal. After the Wyoming Legislature repealed Wyo. Stat. Ann. 20-2-304(b) Clint filed a pro se "Motion to Modify and Correct Unconstitutional Child Support Order." In his motion, Clint argued that the district court's order requiring him to pay child support pursuant to section 20-2-304(b) was unconstitutional because it was rendered pursuant to the now-repealed section 20-2-304(b), which conflicted with federal law. The district court denied the motion. The Supreme Court affirmed, holding that the district court did not abuse its discretion. View "Webb v. State, ex rel. Department of Family Services, Child Support Enforcement Division" on Justia Law

In this complaint brought by Black Diamond Energy and Black Diamond Energy of Delaware (together, the BDE Companies) and seventeen limited partnerships (the Limited Partnerships) the Supreme Court affirmed the judgment of the district court dismissing with prejudice the complaint, holding that the district court did not abuse its discretion in dismissing the case with prejudice.The complaint alleged that S&T Bank's lending policies in the wake of the 2008 economic recession caused severe financial loss to the seventeen limited partnerships (the Limited Partnerships) managed by Black Diamond Energy and Black Diamond Energy of Delaware (together, the BDE Companies). Daniel Groskop, the trustee of a trust formed by the Limited Partnership, was later substituted for the Limited Partnerships as the true party in interest on the condition that the BDE Companies' claims against the Bank be dismissed with prejudice. Due to Groskop's noncompliance with discovery orders and the Wyoming Rules of Civil Procedure, the district court dismissed the case with prejudice. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it concluded that Groskop's violation of two court orders compelling discovery, two orders awarding attorneys' fees, and the failure to fulfill the representative duties associated with Wyo. R. Civ. P. 30(b)(6) required dismissal with prejudice. View "S&T Bank v. Groskop" on Justia Law

The Supreme Court dismissed Petitioner's appeal from an order of the district court dismissing Petitioner's petition seeking exoneration under the Post-Conviction Determination of Factual Innocence Act, Wyo. Stat. Ann. 7-12-401 through 407, holding that this Court lacked jurisdiction because the court's order dismissing Petitioner's petition was not a final appealable order.The district court dismissed Petitioner's petition as deficient under the Act. The Supreme Court affirmed, holding (1) the order dismissing Petitioner's Factual Innocence Act petition following initial review is not a final appealable order; and (2) therefore, this Court lacked jurisdiction over Petitioner's appeal. View "Uden v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated assault and battery and mandatory life sentence, holding that the district court did not err in denying Defendant's motion for a new trial based on ineffective assistance of counsel.In charging Defendant, the State sought a habitual criminal sentencing enhancement under Wyo. Stat. Ann. 6-10-201. After a trial, the jury convicted Defendant and found that he qualified for the habitual criminal enhancement under section 6-101-201(b)(ii). The court sentenced Defendant to life imprisonment. Defendant appealed, arguing that his trial counsel did not communicate with him in a manner that enabled him fully to understand he was facing a life sentence, and this deficiency fell below the standard of professional conduct. The Supreme Court affirmed, holding that Defendant failed to establish prejudice. View "Lewis v. State" on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment and issuing a declaratory judgment and judgment quieting title to real property in favor of Defendants after concluding that Plaintiffs' predecessors in title conveyed a 1/8 mineral interest to Roy Barton in 1989, holding that a 1989 deed conveyed an unrestricted 1/8 mineral interest.Plaintiffs brought this suit, asserting ownership of a royalty interest in the property at issue. The district court granted summary judgment in favor of B&G followed by a declaratory judgment and judgment quieting title to Defendants to a 1/8 mineral interest, including all royalty interests in the 1/8 mineral interest. The Supreme Court affirmed, holding (1) the 1989 deed conveyed an unrestricted mineral interest without reserving a separate royalty interest; and (2) Defendants were not entitled to attorneys' fees and costs. View "Smith v. B&G Royalties" on Justia Law

The Supreme Court reversed the judgment of the district court granting the State's motion to dismiss the charges against Defendant without prejudice, holding that the court abused its discretion in granting the State's Wyo. R. Crim. P. 48 motions.The State filed two separate informations charging Defendant with multiple felonies and misdemeanors. The State later filed motions to join the charges for trial. The district court denied the motions as untimely. Thereafter, the State filed a motion to dismiss the charges without prejudice, noting that it intended to refile the charges in a single information. The district court entered orders of dismissal without prejudice on the basis that the State had provided a reason for its motions. The Supreme Court reversed and remanded for entry of an order dismissing the charges with prejudice, holding that the district court abused its discretion in granting the State's Rule 48 motions where the State was attempting to use dismissal without prejudice to escape from a position of disadvantage caused by its failure diligently to prosecute the case. View "Carabajal v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court finding in favor of Defendant, an anesthesiologist, on Plaintiff's medical negligence claim, holding that the district court did not abuse its discretion when it denied further investigation into a juror's communication with the court bailiff and that the erroneous admission of testimony regarding Defendant's character for truthfulness was harmless.Plaintiff brought this lawsuit claiming that Defendant negligently performed a regional block procedure in preparation for surgery to repair Plaintiff's broken wrist. After a trial, the jury unanimously found Defendant was not negligent. On appeal, Plaintiff argued that the district court erred when it refused to reopen voir dire after a juror spoke with the bailiff and abused its discretion when it allowed a defense witness to testify to Defendant's character for truthfulness. The Supreme Court affirmed, holding (1) Plaintiff's waived her challenge to the participation of the juror at issue, and even if she hadn't, the district court did not abuse its discretion in its treatment of the juror's communication with the bailiff; and (2) the district court abused its discretion in admitting testimony vouching for Defendant's honest character, but this error did not prejudice Plaintiff. View "Lubing v. Tomlinson" on Justia Law