Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court entering a divorce decree in which it awarded a 160-acre parcel of land to Wife and required Husband to satisfy any unpaid property taxes, holding that the court did not abuse its discretion in its property division and assignment of debt or in considering attorney's fees as a factor in its property division.During much of their marriage, Wife and Husband lived on a 160-acre parcel of land owned by Husband's parents. After Husband's parents deeded the parcel to Husband, Wife filed for divorce. The district court awarded the property to Wife and required Husband to satisfy any unpaid property taxes. The Court noted that Wife's requests for an award of attorney's fees during the proceedings were considered in arriving at its division of property. The Supreme Court affirmed, holding that the district court did not abuse its discretion in the disposition of property or in its consideration of attorney's fees. View "Malli v. Malli" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree felony murder and aggravated child abuse but remanded to correct a sentencing error, holding that the district court did not err in denying Defendant's request for two lesser-included offense instructions and that prosecutorial misconduct did not require a new trial.On appeal, Defendant argued that the district court erred in denying his lesser-included offense instructions and that the prosecutor's statements during closing arguments constituted prosecutorial misconduct. The Supreme Court affirmed, holding that the district court did not err in denying Defendant's request for the lesser-included offense instructions and that the prosecutor did not commit misconduct. The Court, however, remanded the case to correct a sentencing error brought to its attention by the State. View "Hartley v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court finding that Buyer had breached a contract for the sale of a lot in a subdivision and ordering Buyer to specifically perform, holding that the district court did not abuse its discretion when it ordered Buyer to specifically perform.After Buyer entered into a contract with Seller for the sale of the lot Buyer decided he no longer wanted to purchase the lot. Seller filed this lawsuit asserting breach of contract and seeking specific performance. Buyer argued that the contract was unenforceable for failing to comply with the statute of frauds. The district court disagreed and entered judgment in favor of Seller, ordering Buyer to specifically perform the contract. The Supreme Court affirmed, holding (1) while the contract failed to comply with the statute of frauds, it was enforceable under the doctrine of partial performance; and (2) the district court did not abuse its discretion when it ordered Buyer to specifically perform. View "Davis v. Harmony Development, LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Defendant's motion to dismiss Plaintiff's action claiming that Defendant failed to perform under a website development agreement, holding that the district court did not abuse its discretion by dismissing the case for improper venue.The district court determined that Teton County, Wyoming was not the proper venue for Plaintiff's suit because a forum selection clause in the parties' Master Services Agreement (MSA) required any claim or suit arising under the agreement to be litigated in Orange County, California. On appeal, Plaintiff argued that the district court improperly resolved disputed issues of fact in determining that the MSA was a valid contract. The Supreme Court affirmed, holding (1) the district court did not decide any material issues of fact; (2) the MSA governed the parties' relationship; and (3) the district court did not abuse its discretion in granting Defendant's motion to dismiss for improper venue. View "Ecocards v. Tekstir, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence seized from his home, holding that the district court did not err when it concluded that the warrantless search of Defendant's home was constitutional under the emergency aid exception to the Fourth Amendment's warrant requirement.After the district court denied his suppression motion, Defendant entered a conditional guilty plea to various drug crimes, including possession of marijuana with intent to deliver, possession of methamphetamine, and possession of marijuana. Defendant appealed the denial of his motion to suppress. The Supreme Court affirmed, holding that intrusion into Defendant's home was lawful and justified by the emergency aid exception to the Fourth Amendment's warrant requirement. View "Ferch v. State" on Justia Law

In this dispute arising from Father's claim that Mother failed to reimburse him for the parties' child's medical costs the Supreme Court affirmed the district court's judgment denying Mother's motion to set aside the court's judgment requiring her to pay not only the medical costs but also the attorney fees and costs Father incurred in collecting the amounts owed and post judgment interest, holding that the district court did not abuse its discretion.Father was given primary custody of the parties' child. The parties were directed to split evenly the child's medical costs. Father later filed a motion for order to show cause why Mother should not be held in contempt for failing to pay one-half of several medical bills Father had presented for payment. The district court entered an award for Father comprising the amount consisting of the balance owing and an award of pre and post judgment interest, as well as attorney fees and costs. Mother moved for relief from the judgment pursuant to Wyo. R. Civ. P. 60(b)(5) and (6). The district court denied the request. The Supreme Court affirmed, holding that Mother was not entitled to relief under rule 60(b)(5) and that the court did not abuse its discretion in awarding the fees and costs. View "Olson v. Schriner" on Justia Law

The Supreme Court affirmed in part and reversed in part the district court's divorce decree, holding that the court did not abuse its discretion in determining child support and dividing marital property but did err by issuing a visitation order to vague to support understanding and compliance.Specifically, the Supreme Court held (1) the district court did not err by finding Father was not voluntarily underemployed; (2) the district court did exceed the bounds of reason in dividing the marital property; and (3) the district court's visitation plan was not sufficiently definite to promote understanding, compliance and enforcement. The Court remanded the case for the district court to order visitation in enough detail to promote understanding and compliance, in accordance with Wyo. Stat. Ann. 20-2-202(a)(i). View "Edwards v. Edwards" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of intimidating and influencing a witness in violation of Wyo. Stat. Ann. 6-5-305(a), holding that Defendant did not show that the prosecutor's comments in rebuttal closing argument or the district court's failure to instruct the jury on voluntariness constituted plain error.Specifically, the Court held (1) the prosecutor did not commit plain error during rebuttal closing argument by improperly shifting the burden of proof to Defendant or stating facts not in evidence; and (2) the district court did not plainly err in failing to instruct the jury that it had to find Defendant acted voluntarily. View "Black v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of misdemeanor interference with a peace officer, holding that Defendant's actions were sufficient to constitute interference with a peace officer and that the circuit court did not err in refusing to give Defendant's proposed jury instruction.Specifically, the Supreme Court held (1) the jury was presented with sufficient evidence to find Defendant guilty of misdemeanor interference with a peace officer; and (2) the circuit court did not err in rejecting Defendant's proposed jury instruction concerning the type of verbal conduct that may constitute interference with a peace officer. View "Garza v. State" on Justia Law

The Supreme Court affirmed the decision of the district court upholding the decision oft he Office of Administrative Hearings (OAH) denying workers' compensation benefits to Appellant, holding that a previous order by the OAH was not a final, appealable order and that collateral estoppel was not applicable.Appellant filed for workers' compensation benefits after his leg was amputated below the knee. The Department of Workforce Services, Workers' Compensation Division (the Division) denied the claim. Appellant appealed, but while the contested case hearing was pending the Division withdrew its denial of benefits. In response, the OAH issued an order vacating the hearing and directing the Division to award workers' compensation benefits. The Division issued a redetermination in favor of Appellant. Appellant's employer objected, and after a contested case hearing, OAH denied workers' compensation benefits. The district court upheld the OAH decision denying benefits. On appeal, Appellant claimed that the first OAH order was a final appealable order awarding benefits and that his employer was collaterally estopped from objecting to the Division's redetermination awarding benefits. The Supreme Court disagreed, holding that the first OAH order was not a "prior adjudication" of workers' compensation benefits and provided no basis to implicate the principle of collateral estoppel. View "Lower v. Peabody Powder River Services, LLC" on Justia Law