Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction and sentence for felony possession of marijuana, holding that Defendant was not prejudiced by the State's breach, if any, of the written plea agreement.In exchange for Defendant's guilty plea to possession of marijuana the State agreed to dismiss a misdemeanor possession of methamphetamine charge and recommend that the trial court suspend Defendant's sentence in favor of supervised probation. The State, however, reneged on its promise to recommend a suspended sentence at sentencing, claiming that it withdrew the plea agreement after the trial court had accepted Defendant's plea because Defendant violated the terms of his bond. The Supreme Court affirmed, holding that Defendant failed to show that he was prejudiced by the State's breach, if any. View "Grater v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Wife a divorce after she defaulted on Husband's counterclaim that he was the aggrieved party, holding that, under the circumstances, the court did not abuse its discretion.After Wife filed a complaint for divorce Husband answered the complaint and counterclaimed that he was the aggrieved party entitled to divorce. After Wife failed to timely answer Husband applied for entry of default on his counterclaim. The district court entered default on the same day it entered its decree granting Wife's complaint for divorce. Husband appealed, claiming that he was the aggrieved party entitled to divorce. The Supreme Court affirmed, holding that, viewing the record in the light most favorable to Wife, the court did not abuse its discretion in determining that she was the aggrieved party entitled to divorce. View "Goswick v. Goswick" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for one count of sexual abuse of a minor in the second degree and one count of child endangerment, holding that the district court did not abuse its discretion when it did not evaluate taint sua sponte or when it denied Defendant's motion to continue trial, and the prosecutor did not commit prejudicial misconduct.Specifically, the Supreme Court held (1) the district court did not abuse its discretion when it did not evaluate taint during the competency hearing; (2) the district court did not abuse its discretion when it denied Defendant's motion to continue trial; (3) the prosecutor did not commit prejudicial misconduct; and (4) the district court did not err by denying Defendant's motion for a new trial based on ineffective assistance of counsel. View "Shields v. State" on Justia Law

The Supreme Court dismissed this appeal from the district court's grant of summary judgment to Appellee, holding that because the district court's order granting summary judgment did not resolve all outstanding issues before it, it was not an appealable order under Rule 1.05 of the Wyoming Rules of Appellate Procedure (W.R.A.P.).Michael G. McDill, as trustee of the Phyllis V. McDill Revocable Trust, filed a petition for instructions seeking confirmation that the Trust's no contest clause prohibited Thomas P. McDill, Jr. from taking under the Trust. The district court granted Michael's motion for summary judgment and his petition for instructions. Thomas appealed. The Supreme Court dismissed the appeal, holding (1) the district court's order granting Michael's summary judgment motion was not an appealable order under W.R.A.P. 1.05, and therefore, this Court lacked jurisdiction to hear the appeal; and (2) Michael was entitled to attorney fees and costs under W.R.A.P. 1.03 and 10.05. View "McDill v. McDill" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree sexual assault and incest for acts committed against KW, his eighteen-year-old stepdaughter, holding that the district court's error admitting evidence of uncharged misconduct which the State had not provided notice of and which had not been subject to a Wyo. R. Evid. 404(b) admissibility analysis was harmless.Specifically, the Supreme Court held that, as in Broberg v. State, 428 P.3d 167 (Wyo. 2018), the admission of the 404(b) evidence was error, but there was no reasonable probability that the verdict against Defendant would have been more favorable had the state's section 404(b) evidence not been admitted. View "Blanchard v. State" on Justia Law

The Supreme Court affirmed the judgment of the Teton County Board of County Commissioners approving an application by the Teton Raptor Center for an amended conditional use permit (CUP) to expand the use of its property, holding that the Board's decision was not arbitrary and capricious and did not violate the law.In 2008, after obtaining variances to address nonconformities on structures on its property the Raptor Center obtained a CUP allowing the Raptor Center to operate its bird care and education facility. In 2017, the Raptor Center decided to expand its use of the site and applied to amend its 2008 CUP. The Board approved the application. Petitioners - nearby landowners and other parties - appealed, and the district court affirmed. The Supreme Court affirmed, holding (1) Petitioners had standing to appeal the Board's decision; and (2) the Board reasonably concluded that the amended CUP complied with all relevant standards and resolutions and that the amended CUP substantially complied with the requirements of the 2008 variance. View "HB Family Limited Partnership v. Teton County Board of County Commissioners" on Justia Law

The Supreme Court affirmed the judgment of the district court against Plaintiff on her negligent credentialing claim against the Board of Trustees of the Memorial Hospital of Carbon County (the Hospital), holding that the default judgment against Eric Dash, M.D. did not estop the Hospital from contesting his negligence.Plaintiff filed a complaint alleging negligence against Dr. Dash and negligent credentialing and vicarious liability against the Hospital. When Dr. Dash failed to answer or otherwise defend the district court entered a default judgment against him. A two-phase jury trial was subsequently on the negligent credentialing claim against the Hospital, with the first phase trying the question of Dr. Dash's negligence. The jury returned a verdict finding no negligence. The district court then entered judgment in favor of the Hospital, finding that the negligence of Dr. Dash was a prerequisite to liability against the Hospital for negligent credentialing. The Supreme Court affirmed, holding that the district court (1) did not err when it found the default judgment against Dr. Dash was not binding on the Hospital on the basis of collateral estoppel or issue preclusion; and (2) did not abuse its discretion when it bifurcated the issue of Dr. Dash's negligence from the negligent credentialing claim against the Hospital. View "Loeffel v. Dash" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing EOG Resources, Inc.'s complaint under the Wyoming Eminent Domain Act seeking to condemn a seventy-acre pipeline easement on the grounds that EOG had not complied with the Act's good-faith negotiation requirement, holding that, under the facts and circumstances of this case, EOG did not satisfy the good-faith negotiation requirement.After conducting oil and gas operations on the Floyd C. Reno & Sons, Inc.'s (Reno) ranch pursuant to a surface use agreement, EOG proposed an amended surface use agreement that would grant it additional rights over the property. Reno rejected EOG's offer. Thereafter, EOG filed an amended complaint seeking to condemn seventy acres. The district court held that EOG failed to satisfy the Act's good-faith negotiation requirement and dismissed the complaint. The Supreme Court affirmed, holding (1) there must be a sufficient resemblance to the property sought to be condemned and the property described in the offer to allow a court to conclude that the subject of the negotiation was clear to both parties and that the offer might have been accepted as it related to the property ultimately sought to be condemned; and (2) the record supported the conclusion that EOG failed to meet that standard. View "EOG Resources, Inc. v. Floyd C. Reno & Sons, Inc." on Justia Law

The Supreme Court reversed in part and affirmed in part the district court's order finding Mother in contempt, holding that the district court abused its discretion in holding Mother in contempt for violations that had been remedied before the case was filed and in finding Mother in contempt when Father failed to meet his burden of proof.The district court held Mother in contempt for mishandling accounts held for the parties' children and for failing to pay her share of the children's medical expenses. The court then awarded attorney's fees to Father and denied Mother's motion for sanctions. The Supreme Court reversed in part, holding (1) the district court abused its discretion by finding Mother in contempt for mishandling one child's brokerage account and for failing to prove quarterly statements for four college accounts held for the children because the violations were remedied before the case was filed; (2) the record did not contain clear and convincing evidence that Mother violated the order requiring her to pay her share of uncovered medical bills; (3) there was no basis for an award of attorney's fees; and (4) the district court correctly denied Mother's motion for sanctions. View "Breen v. Black" on Justia Law

The Supreme Court affirmed the judgment of the district court denying as untimely Kathleen Kerbs' motion to intervene in an action brought by her husband, Scott Kerbs, against Carl, Kip, and Nadene Kerbs for dissolution of the Kerbs Four Bar Ranch Partnership, holding that the district court did not abuse its discretion by denying the motion to intervene.Carl and Nadene formed the Kerbs Four Bar Ranch Partnership with Scott and Kip. Carl and Nadene gifted Scott, Kathleen, Kip, and Kip's wife, Rebecca an interest in the partnership. Scott later filed an action against the partnership, Kip, Carl, and Nadene seeking dissolution of the partnership. The parties agreed on a procedure to dissolve the partnership, and the agreement was memorialized in a dissolution order. Kathleen later filed a motion to intervene. The district court denied the motion as untimely. The Supreme Court affirmed, holding that, under the circumstances, the district court reasonably concluded that Kathleen's motion to intervene was untimely. View "Kerbs v. Kerbs" on Justia Law