Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court forfeiting $470,040 in United States currency seized from Robert Miller to the State under the Wyoming Controlled Substances Act, Wyo. Stat. Ann. 35-7-1001 to -1060, holding that the State unreasonably delayed filing the action.Miller filed a motion to dismiss the case on grounds that the State's 270-day delay in instituting proceedings violated the statutory requirement that the State institute such proceedings "promptly" and his due process rights under the United States Constitution. The district court denied the motion and forfeited the currency to the State. The Supreme Court applied the four-factor balancing test from Barker v. Wingo, 407 U.S. 514 (1972), to assess whether Miller's right to due process had been violated. The Court then reversed and remanded for dismissal with prejudice, holding that the State failed "promptly" to institute the forfeiture proceedings, in violation of section 35-7-1049(c) and Miller's right to due process under the federal Constitution. View "Miller v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of two counts of sexual intrusion on a victim under Wyo. Stat. Ann. 6-2-314(a)(i), holding that the district court did not err when it admitted testimony under Wyo. R. Evid. 404(b) and 801(d)(1)(B) and did not violate Defendant's rights under the Confrontation Clause when it allowed the State to amend the felony information after the State had presented its witnesses.Specifically, the Supreme Court held (1) the district court did not abuse its discretion in admitting evidence of other acts under Rule 404(b) or in allowing the victim's prior consistent statements under Rule 801(d)(1)(B); and (2) the amendment to the felony information without a continuance did not deny Defendant his right to effectively cross-examine the witnesses or prejudice his defense. View "LaJeunesse v. State" on Justia Law

The Supreme Court reversed in part the judgment of the district court granting summary judgment in favor of Plaintiff on his adverse possession claim and in favor of Defendant on Plaintiff's prescriptive easement and implied easement claims, holding that material issues of fact precluded summary judgment in favor of Plaintiff on his adverse possession claim and this error hindered review of the prescriptive easement claim.At issue was the property boundary between two residential lots connected by a shared driveway. Plaintiff claimed that he had adversely possessed a thirty-inch strip of Defendant's driveway, that he had an easement over the entire driveway, and that Defendant had intentionally trespassed on the adversely possessed portion of his property. The district court granted summary judgment for Plaintiff on the adverse possession claim and granted summary judgment for Defendant on the prescriptive easement and implied easement claims. The Supreme Court reversed in part, holding (1) the court erred in granting summary judgment on the adverse possession claim because issues of material fact concerning hostility existed; (2) because the prescriptive easement cannot be resolved independent of the adverse possession claim, review on this claim was precluded; and (3) the district court did not err in granting summary judgment for Defendant on the implied easement claim. View "Hulme v. O'Hare" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing without prejudice Grandmother's petition seeking temporary guardianship of Grandchild for failure to prosecute, holding that the district court did not abuse its discretion.Grandmother filed her petition for temporary guardianship on May 9, 2017. On June 26, 2017, the district court issued an order to show cause, noting that no action had been taken on the petition in more than two years and ordering Grandmother to show cause why the matter should not be dismissed. The court subsequently entered an order dismissing the petition with prejudice. The Supreme Court affirmed, holding that the district court did not abuse its discretion in dismissing the petition. View "In re Interest of Bass" on Justia Law

In this case concerning a "race to permit" dispute between the parties in this case, both of whom held mineral interests in certain drilling and spacing units and both of whom wanted to be the "operator" of those units, the Supreme Court reversed the judgment of the district court granting Defendant's motion to dismiss for lack of subject matter jurisdiction, holding that the district court and not the Wyoming Oil and Gas Conservation Commission was the proper forum to resolve this case.Defendant won the race to permit and obtained operator status over the lands at issue. Plaintiff filed a complaint alleging that Defendant violated Wyo. Stat. Ann. 40-27-101, which prohibits a party from trespassing on private lands to unlawfully collect resource data. The district court granted Defendant's motion to dismiss, concluding that the Commission had primary jurisdiction to resolve the dispute and that Plaintiff failed to exhaust its administrative remedies. The Supreme Court reversed, holding (1) Plaintiff sufficiently pleaded standing under section 40-27-101 and the Declaratory Judgments Act; (2) the district court abused in dismissing the complaint for failure to exhaust administrative remedies because the Commission did not have jurisdiction to consider Plaintiff's civil trespass claim; and (3) the court abused its discretion in relying on the primary jurisdiction doctrine. View "Devon Energy Production, LP v. Grayson Mill Operating, LLC" on Justia Law

The Supreme Court affirmed the order of the district court establishing paternity, custody, visitation and child support, holding that the district court did not abuse its discretion in any aspects of its child support apportionment.Specifically, the Supreme Court held (1) the district court did not abuse its discretion in failing to make the support obligation retroactive; (2) the district court did not abuse its discretion by declining to impute Father's income at the amount he earned in a previous, higher-paying position; and (3) Mother's arguments regarding allocation of responsibility for the child's medical insurance and medical costs were not ripe for review. View "Shipley v. Smith" on Justia Law

The Supreme Court affirmed the order of the district court modifying visitation and child support after Mother moved to Idaho, holding that the district court did not abuse its discretion.After Mother moved to Idaho from Wyoming Father petitioned to modify custody, visitation and support, requesting physical and residential custody of the parties' daughter. Mother counterclaimed to maintain primary physical custody of the child. The district court then issued a final order concluding that Mother's move constituted a material change in circumstances and that it was in the child's best interest for Father to have primary physical and residential custody of the child. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it (1) determined that it was in the child's best interest for Father to have primary physical and residential custody of the child after she enters kindergarten; and (2) established the visitation plan. View "Walsh v. Smith" on Justia Law

In property dispute, the Supreme Court affirmed the judgment of the district court entering summary judgment in favor of The Nature Conservancy finding a conservation easement unambiguously burdened two parcels of property thereby limiting what the owner could construct on those parcels, holding that the district court was correct in entering summary judgment in favor of the Conservancy.Appellants, who owned the two parcels of land at issue, sought declaratory relief after the Conservancy, the administrator of the conservation easement, rejected Appellants' plan to construct buildings on each of the two parcels. The Conservancy counterclaimed for declaratory relief seeking a declaration that the conservation easement burdened and encumbered Appellants' parcels of property and limited construction on the property. The district court granted summary judgment and entered judgment on the pleadings in favor of the Conservancy. The Supreme Court affirmed, holding (1) the district court did not err in entering summary judgment for the Conservancy; and (2) the district court did not err when it entered judgment on the pleadings dismissing Appellants' claims for breach of contract and breach of the covenant of good faith and fair dealing. View "Four B Properties, LLC v. Nature Conservancy" on Justia Law

The Supreme Court affirmed the order of the district court denying a petition filed by Father and Stepmother for adoption of Father and Mother's two minor children pursuant to Wyo. Stat. Ann. 1-22-110(a)(ix), holding that the district court did not abuse its discretion in determining that Mother's failure to pay seventy percent or more of court-ordered child support for a two-year period was not willful.Father and Stepmother petitioned the district court to allow Stepmother to adopt Father and Mother's two minor children based on Mother's willful failure to pay at least seventy percent of court-ordered support for a two-year period. The district court denied the petition, determining that Mother's failure to pay was not willful. The Supreme Court affirmed, holding that the evidence was sufficient to support the district court's finding that Mother's failure to meet her child support obligation was not willful. View "CML v. ADBL" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony possession of marijuana, holding that the State's trial evidence was sufficient to establish that Defendant possessed the marijuana.Defendant was convicted of violating Wyo. Stat. Ann. 35-7-1031(c)(iii), which makes it a felony for a person to knowingly or intentionally have in his possession more than three ounces of marijuana in plant form. On appeal, Defendant argued that the State did not prove he exercised dominion and control over the marijuana. The Supreme Court affirmed, holding that the trial evidence was clearly sufficient to support the jury's conclusion that Defendant constructively possessed more than three ounces of marijuana. View "Huckins v. State" on Justia Law