Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court remanded this matter to the district court for correction of its written sentencing order, holding that the district court's written sentence differed from its oral pronouncement, requiring a remand.Defendant pled no contest to aggravated battery. The district court imposed a three to five year sentence. The court then stated that it would suspend incarceration and place Defendant on supervised probation for a period of three years. Thereafter, the district court signed a written judgment and sentence stating that "probation shall continue for a period of 5 years...." The Supreme Court affirmed in part and remanded in part, holding (1) the district court did not abuse its discretion when it denied Defendant's motion to withdraw his no contest plea; and (2) the sentence was improper to the extent it differed from the district court's oral pronouncement. View "Wanberg v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree sexual abuse of a minor, third-degree sexual abuse of a minor, and incest, holding that the district court did not abuse its discretion in finding the victim competent to testify as a witness and that Defendant was not denied his constitutional right to confront a witness against him.On appeal, Defendant argued that the district court abused its discretion in finding the victim competent to testify and that, due to her incompetency, as well as her behavior at trial, he was denied his right to confront her as a witness. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in finding the victim competent to testify; (2) Defendant was not denied his right to effectively cross-examine the victim; and (3) any error was harmless beyond a reasonable doubt. View "Tamblyn v. State" on Justia Law

In this contract dispute, the Supreme Court affirmed the order of the district court dismissing H&P Advisory Limited's complaint against Randgold Resources, Limited and Barrick Gold Corporation for lack of personal jurisdiction, holding that the undisputed facts and all reasonable inferences in H&P's favor did not support personal jurisdiction over Defendants in Wyoming.Randgold, a Jersey (Channel Islands) corporation, and Barrick, a Canada corporation, were two of the world's largest gold mining companies. H&P, a United Kingdom private limited company, served as a neutral broker between the two companies in a merger deal. Those involved in the merger met in Jackson, Wyoming to participate in a series of negotiations. Randgold and Barrick subsequently announced the merger but did not list H&P as an advisor and offered to pay H&P a "small fee" for its role in the merger. H&P sued Randgold and Barrick in the Ninth Judicial District in and for Teton County, Wyoming alleging breach of contract. The district court dismissed the complaint on personal jurisdiction grounds. The Supreme Court affirmed, holding that the district court correctly concluded that it lacked specific personal jurisdiction over Defendants. View "H&P Advisory Ltd. v. Randgold Resources Ltd." on Justia Law

The Supreme Court affirmed Defendant's convictions for murder in the first degree and attempted murder in the first degree, holding that Defendant was not denied his right to a speedy trial or his right to a fair trial due to ineffective assistance of counsel or prosecutorial misconduct.Specifically, the Supreme Court held (1) Defendant was not denied his statutory or constitutional right to a speedy trial; (2) Defendant failed to establish that he was denied his constitutional right to effective assistance of counsel; and (3) Defendant failed to establish that he was denied his constitutional right to due process of law or a fair trial due to prosecutorial misconduct. View "Fairbourn v. State" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Plaintiffs' lawsuit against the Wyoming State Hospital and its staff for medical malpractice, negligence, and wrongful death, holding that Plaintiffs' allegations were sufficient to survive a motion to dismiss and that the Hospital and Dr. Sarah Rogers were not immune from suit.Robert Anderson died while in the custody of the Hospital. Prior to his death, Anderson had been adopted by his paternal grandmother, who had since died. Robert Craft, Anderson's biological father and his adoptive brother, and Sabrina Craft, Anderson's appointed personal representative and Robert's wife, brought this action. The district court dismissed the complaint, holding (1) the Crafts lacked standing and had failed to state a claim under Wyo. R. Civ. P. 12(b)(6); (2) the Crafts were not qualified death beneficiaries because of Anderson's adoption; and (3) Dr. Rogers and the Hospital were immune from suit under the Wyoming Governmental Claims Act (WGCA). The Supreme Court reversed, holding (1) as Anderson's adoptive brother, Craft was a qualified wrongful death beneficiary; (2) Plaintiffs' allegations of medical malpractice, negligence, and medical malpractice were sufficient to survive a motion to dismiss; and (3) Dr. Rogers and the Hospital were not immune from suit. View "Craft v. State ex rel. Wyo. Department of Health" on Justia Law

The Supreme Court reversed the judgment of the district court denying for lack of subject matter jurisdiction Petitioner's petition for an order recognizing her change of sex and gender so that she could amend her birth certificate, holding that the district court had subject matter jurisdiction.Petitioner's birth certificate identified her as male, but Petitioner identified and held herself out as female. Petitioner petitioned the district court for an order recognizing her change of sex and gender pursuant to its power of general jurisdiction and Wyo. Stat. Ann. 35-1-424(a). The district court denied the petition, concluding that neither the Wyoming Constitution, Wyo. Stat. Ann. 35-1-424, nor the rules of the Wyoming Department of Health (WDOH) granted it subject matter jurisdiction. The Supreme Court reversed, holding (1) the Wyoming Constitution and precedent require a presumption in favor of district court subject matter jurisdiction; (2) the Vital Records Act provides the district court subject matter jurisdiction to address Petitioner's petition for sex change; and (3) therefore, the district court has subject matter jurisdiction. View "MH v. First Judicial District Court of Laramie County" on Justia Law

The Supreme Court affirmed the decision of the Medical Commission upholding that decision of the Wyoming Workers' Safety and Compensation Division denying workers' compensation benefits because Appellant failed to establish a causal connection between his injury and employment, holding that the Commission's decision was not contrary to the overwhelming weight of the evidence.The Division denied benefits because Appellant did not submit evidence establishing a causal connection between his injury and employment as required by Wyo. Stat. Ann. 27-14-603(a). The Commission upheld the denial of benefits after rejecting the opinions of Appellant's medical experts. The Supreme Court affirmed, holding that the Commission's determination that Appellant failed to meet his burden under section 27-14-603(a) for an injury occurring over a substantial period of time was not contrary to the overwhelming weight of the evidence. View "McMillan v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

In this dispute over an accessway traversing Patricia Douglas' property the Supreme Court affirmed the decision of the district court holding that the accessway was a driveway subject to a conservation easement's development limitation, holding that the district court did not err.Jackson Hole Land Trust (JHLT) held the conversation easement, which limited the area that could be developed on Douglas' property. Douglas sought a declaration that the accessway crossing her property was a road rather than a driveway and thus should not be counted toward the total developed area. The district court granted summary judgment in favor of JHLT but declined to award it costs and attorneys' fees. The Supreme Court affirmed, holding (1) the accessway traversing Douglas' property is a driveway subject to the conservation easement's site development limitation; and (2) the easement terms do not provide for the award of costs and attorneys' fees for a declaratory judgment action. View "Jackson Hole Land Trust v. Douglas" on Justia Law

The Supreme Court affirmed the jury's verdict in favor of Dr. Ronald E. Stevens on Anesthesiology Consultants of Cheyenne, LLC's (ACC) claims for brach of fiduciary duties, breach of the covenant of good faith and fair dealing and breach of contract, holding that there was no error.ACC claimed that Dr. Stevens, its former manager and member, took for himself ACC's business opportunity to provide anesthesiology services to an eye surgery center. When this case was first before the Supreme Court, the Court concluded that the district court erred in granting ACC summary judgment because genuine issues of material fact existed as to ACC's covenant of good faith and fair dealing and breach of fiduciary duty claims. On remand, the jury rendered a verdict in favor of Dr. Stevens on all claims. The Supreme Court affirmed, holding (1) sufficient evidence supported the jury's verdict that Dr. Stevens did not breach his fiduciary duties of loyalty and care or the covenant of good faith and fair dealing; and (2) because the law of the case doctrine did not apply to the district court's summary judgment ruling on ACC's breach of contract claim, the court properly submitted that claim to the jury. View "Anesthesiology Consultants of Cheyenne, LLC v. Stevens" on Justia Law

The Supreme Court affirmed Defendant's convictions on three counts of second-degree attempted murder, thirteen counts of aggravated assault and battery, and one count of interference with a peace officer, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the district court’s finding of no discriminatory purpose in the State’s exercise of peremptory challenges was not clearly erroneous; (2) Defendant's right to a fair trial was not violated when the district court refused to individually query jurors about their exposure to pretrial publicity; (3) the district court did not abuse its discretion when it denied Defendant’s pretrial motion for a continuance; (4) the district court did not err in denying Defendant's motion for judgment of acquittal; (5) Defendant did not receive ineffective assistance of counsel; and (6) because there was no error, cumulative error did not deprive Defendant of a fair trial. View "Pickering v. State" on Justia Law