Justia Wyoming Supreme Court Opinion Summaries

A police officer responded to a hotel where a mother, RN, was intoxicated and with her six-year-old son, JN. Due to her intoxication and the presence of a violent boyfriend at home, JN was taken into protective custody. RN tested positive for amphetamines and had a high blood alcohol content. The State filed a neglect petition, and JN was placed in foster care. The initial permanency plan was family reunification, and RN was required to follow a case plan that included maintaining sobriety and addressing her relationship with her boyfriend.The juvenile court held a shelter care hearing and placed JN in the State's temporary custody. RN made some progress but failed to maintain sobriety and continued her relationship with her boyfriend. The court extended the consent decree to allow more time for RN to comply with the case plan. However, RN missed drug tests, tested positive for methamphetamine, and failed to appear at a hearing, leading to the revocation of the consent decree and the adjudication of neglect. The permanency plan was updated to require inpatient drug treatment, but RN did not check into treatment until the day before the permanency hearing.The Wyoming Supreme Court previously reversed the juvenile court's order changing the permanency plan to adoption due to the lack of a reasonable efforts determination by the Department of Family Services (DFS). On remand, the juvenile court determined that DFS had made reasonable efforts based on the evidence from the original hearing and reaffirmed the change in the permanency plan. The court found that despite RN's bond with JN, her inability to maintain sobriety and provide a stable environment justified the change to adoption. The Wyoming Supreme Court affirmed the juvenile court's decision, finding sufficient evidence that the change was in JN's best interests. View "RN v. The State of Wyoming" on Justia Law

A group of property owners and entities challenged the Albany County Board of County Commissioners' amendments to zoning regulations known as the Aquifer Protection Overlay Zone (APOZ). The amendments aimed to protect the Casper Aquifer, which supplies drinking water to many residents in Albany County, including those in the City of Laramie. The property owners argued that the Board's adoption of the amendments was arbitrary, capricious, and exceeded its authority.The District Court of Albany County dismissed the petitions for review, concluding that it lacked jurisdiction because the amendments were legislative acts and not reviewable under the Wyoming Administrative Procedure Act (WAPA). The property owners and entities appealed, arguing that the Board's actions were reviewable and that the Board lacked the authority to adopt the amendments.The Wyoming Supreme Court reviewed the case and clarified that there is no common law or general statutory exception to judicial review of agency legislative actions. The court held that the characterization of the Board’s action as legislative or adjudicatory dictates the scope and nature of the review. The court concluded that the district court has jurisdiction to review the APOZ amendments and remanded the case to the district court to conduct an analysis in conformance with the opinion. The court emphasized that judicial review of agency legislative actions is limited by the separation of powers doctrine and should focus on whether the actions were contrary to constitutional rights, not in accordance with the law, in excess of statutory authority, or divergent from the agency's own rules. View "Warren Livestock, LLC v. Board of County Commissions" on Justia Law

William R. Durkin, III, pled guilty to felony theft and felony property destruction and was sentenced to concurrent terms of five to eight years in prison, which were suspended in favor of a split sentence of one year in county jail followed by four to five years of supervised probation. After moving to Michigan, Durkin violated his probation by using alcohol and cocaine. As a sanction, Michigan Probation required him to complete the Tri County Community Adjudication Program (TRICAP), a probation residential center. Durkin spent 107 days at TRICAP but later violated probation again by drinking alcohol and absconding. Wyoming authorities filed a motion to revoke his probation, and Durkin was arrested in 2023.The District Court of Converse County revoked Durkin's probation and imposed his suspended prison sentences, reducing them to concurrent terms of four to six years. The court credited him for 413 days served in official detention in Wyoming but denied credit for the 107 days spent at TRICAP. Durkin appealed the revocation order and filed a motion to correct his sentences, arguing that the court erred by not crediting his time at TRICAP. The district court denied his motion, and Durkin appealed this decision as well.The Supreme Court of Wyoming reviewed the case and affirmed the district court's decision. The court held that Durkin was not in "official detention" while at TRICAP, as it was not an approved Wyoming Adult Community Corrections (ACC) program and did not subject him to escape charges under Wyoming law. Consequently, Durkin was not entitled to credit against his prison sentences for the time spent at TRICAP. The court concluded that the district court's sentences were legal and properly denied Durkin's motion to correct his sentences. View "Durkin v. The State of Wyoming" on Justia Law

In the early morning of July 8, 2022, Officer Luke Thorp of the Mills Police Department responded to a report of an unconscious male in a truck with syringes on the ground nearby. Upon arrival, Officer Thorp found Travis Dean Schaub in the vehicle, appearing disoriented and exhibiting signs of intoxication. After a slow and difficult exit from the vehicle, Schaub refused consent to a search, but Officer Thorp proceeded to search him, finding methamphetamine. Schaub was then handcuffed, placed in the patrol vehicle, and read his Miranda rights.The District Court of Natrona County reviewed Schaub’s motion to suppress the evidence obtained during the search, arguing it exceeded the scope of an investigatory stop and lacked a warrant. The State contended that the search was justified as incident to a lawful arrest for public intoxication. The district court agreed with the State, finding that Officer Thorp had probable cause to arrest Schaub for public intoxication under the Mills Municipal Code, and thus the search was lawful.The Supreme Court of Wyoming reviewed the case and affirmed the district court’s decision. The court held that Officer Thorp had probable cause to arrest Schaub based on his observed intoxication and the presence of syringes. The court further held that the search was valid as incident to a lawful arrest, even though it preceded the formal arrest by a few minutes. The court emphasized that the Fourth Amendment does not require the arrest to precede the search, as long as the arrest follows quickly and there is probable cause. Therefore, the denial of Schaub’s motion to suppress was upheld. View "Schaub v. The State of Wyoming" on Justia Law

On January 12, 2023, Officer Kevin Valentine of the Buffalo Police Department responded to a report of a suspicious vehicle at a gas station. The vehicle, a white Toyota Camry with Montana plates, had been parked at a pump for 30-45 minutes with its windows covered. Upon arrival, Officer Valentine observed Robert Labbe exiting the vehicle and asked him to return to the car for questioning. Labbe did not have his driver’s license, and a check revealed his license was suspended. The passenger, Elizabeth Davison, also had a suspended license and an active warrant.Officer Dustin Matthews arrived to assist, and after arresting Davison, the officers requested a canine unit. Deputy Quinn Maddox and his drug detection dog, Lucy, arrived 18 minutes later. Lucy alerted to the presence of drugs, leading to a search that uncovered marijuana, paraphernalia, and suspected fentanyl pills. The vehicle was towed for a more thorough search, revealing significant quantities of methamphetamine, fentanyl pills, marijuana, and THC. Labbe was charged with multiple counts of possession of controlled substances.Labbe filed a motion to suppress the evidence, arguing the drugs were found as a result of an illegal detention. The District Court of Johnson County denied the motion, stating the vehicle was in a public parking lot and law enforcement did not need reasonable suspicion, probable cause, or consent for a canine sniff. Labbe entered conditional guilty pleas to two felony counts, reserving the right to appeal the suppression ruling.The Wyoming Supreme Court affirmed the district court’s decision. The court held that the canine sniff was lawful as it occurred in a public place, and the dog’s alert provided probable cause for the search. The court found the evidence was not obtained as a result of an unlawful detention, making the search and subsequent seizure of drugs lawful. View "Labbe v. The State of Wyoming" on Justia Law

Kerry and Jeanie Cooper entered into a five-year lease agreement with James and Melisa Crouch to lease farmland for pasturing cattle and growing crops. The lease was set to expire in February 2022, but the Crouches terminated it early, citing the Coopers' failure to employ standard best management practices. The Coopers filed a lawsuit for breach of contract, claiming they were not given adequate notice or an opportunity to cure any alleged default as required by the lease.The District Court of Fremont County found that the Crouches breached the lease by failing to provide the required notice and opportunity to cure. The court awarded the Coopers $153,772.05 in damages, which included costs for feed, supplements, trucking, and replacement pasture. The court also reduced the damages by $24,650.35 for the Coopers' failure to mitigate damages by selling leftover hay.The Supreme Court of Wyoming reviewed the case and affirmed the district court's findings. The court held that the Crouches did not provide the Coopers with a meaningful opportunity to cure the alleged default, as the termination letter did not specify how to remedy the issues. The court also rejected the Crouches' first-to-breach defense, stating that they could not rely on the Coopers' alleged breach to excuse their own failure to provide proper notice.However, the Supreme Court found that the district court had erroneously included the costs of the pasture leases twice in its damages calculation. The court remanded the case with instructions to reduce the damages award by $2,660.60, affirming the decision in all other respects. View "Crouch v. Cooper" on Justia Law

On March 4, 2023, Officer Brandon LaPointe stopped Antonio Kaye Lee's vehicle for illegally tinted windows. After confirming the tint violation, Officer LaPointe called for a canine unit, which alerted to narcotics. A search revealed methamphetamine and drug paraphernalia. When informed of his arrest, Mr. Lee resisted, leading to a struggle during which officers claimed he attempted to grab their firearms. Mr. Lee was charged with multiple offenses, including two counts of attempting to disarm a peace officer.The District Court of Sweetwater County presided over the trial. Mr. Lee admitted to the drug-related charges but denied attempting to disarm the officers, asserting he was merely trying to escape. The officers testified that Mr. Lee grabbed their firearms during the struggle. The jury found Mr. Lee guilty on all counts, and he was sentenced to concurrent prison terms for the misdemeanors and the attempted disarming charges.The Wyoming Supreme Court reviewed the case, focusing on whether the district court erred by not instructing the jury on all elements of attempting to disarm a peace officer, specifically the requirement of a "substantial step" toward committing the crime. The court found that the district court's failure to include this element in the jury instructions constituted plain error. The Supreme Court held that this omission materially prejudiced Mr. Lee because the jury might not have found he took a substantial step toward disarming the officers, given the conflicting testimonies. Consequently, the Wyoming Supreme Court reversed the district court's decision. View "Lee v. The State of Wyoming" on Justia Law

The case involves a divorce between Guy Morrison, III (Husband) and Tami Hinson-Morrison (Wife), who married in 2007. Before the marriage, they signed a premarital agreement stating that each party would retain their individual property, any property acquired from the proceeds or appreciation of their premarital property, and any property acquired by gift or inheritance. During the marriage, Husband formed three oil and gas companies and made various financial contributions to Wife's businesses and properties. Wife filed for divorce in 2022, leading to disputes over the interpretation and application of the premarital agreement and the equitable distribution of assets and debts.The District Court of Campbell County found the premarital agreement clear and unambiguous, except for its silence on commingling of funds. The court ruled that Husband's financial contributions to Wife's properties were spousal gifts and did not warrant compensation. The court divided the remaining marital assets and debts equitably, awarding Husband his businesses and other assets, while Wife retained her businesses and the marital home. The court also ordered the parties to file joint tax returns for 2021 and 2022 and bear their respective tax obligations proportionally.The Supreme Court of Wyoming affirmed the district court's decision. It held that the premarital agreement was clear and enforceable, and the district court correctly interpreted it without adding a commingling provision. The court also found no abuse of discretion in the equitable distribution of assets and debts, noting that the division left both parties in a comfortable financial position. The court declined to award Wife attorney fees, as the fee-shifting provision in the premarital agreement did not apply to the divorce proceedings. View "Morrison v. Hinson-Morrison" on Justia Law

High Plains Power, a cooperatively owned utility in central Wyoming, proposed a tariff revision to the Wyoming Public Service Commission (PSC) in August 2022. The revision aimed to change the compensation rate for customer-generators—members who generate electricity through small net metering systems—from a retail rate credit to an avoided cost rate, which is lower. Powder River Basin Resource Council and Wyoming Outdoor Council opposed this change, arguing it would unfairly reduce compensation for customer-generators.The PSC held a hearing in May 2023, where both parties presented evidence and testimony. The PSC approved the tariff revision on a two-to-one vote, with Chairman Throne dissenting. The appellants then petitioned the district court for review, which certified the case to the Wyoming Supreme Court.The Wyoming Supreme Court reviewed the case de novo and found that the PSC misinterpreted the relevant statute and failed to perform its ratemaking function. The court held that the PSC erred in presuming that the avoided cost rate was a just and reasonable rate for monthly compensation under Wyoming Statute § 37-16-103(a)(iii). The court emphasized that the statute does not specify the value of monthly credits or compensation, leaving it to the PSC to determine through its ratemaking process. The court concluded that the PSC did not evaluate the evidence or consider whether the proposed change served the public interest. Consequently, the Wyoming Supreme Court reversed the PSC's decision. View "Powder River Basin Resource Council v. Wyoming Public Service Commission" on Justia Law

Jarrett Gage Vargas was convicted of aggravated child abuse after his three-month-old foster child, RW, suffered severe injuries while in his care. On October 15, 2021, RW began seizing, prompting Vargas to call 911. Medical examinations revealed both acute and chronic subdural hematomas, a brain contusion, and retinal hemorrhages. Vargas admitted to handling RW roughly and bouncing him aggressively. The State charged Vargas with aggravated child abuse, arguing that RW’s injuries were caused by nonaccidental trauma.The District Court of Natrona County presided over the trial. The State presented medical experts who testified that RW’s injuries were consistent with abusive head trauma. Vargas countered with his own medical expert, who suggested that RW’s injuries could have been caused by a preexisting condition called external hydrocephalus, which could lead to subdural hematomas from benign activities. The jury found Vargas guilty of aggravated child abuse, and he was sentenced to 10-15 years in prison. Vargas filed a direct appeal and a motion for a new trial, claiming ineffective assistance of counsel. The district court denied the motion, and Vargas appealed that denial as well. The appeals were consolidated, but Vargas did not pursue the ineffective assistance claim further.The Wyoming Supreme Court reviewed the case, focusing on whether the district court erred in rejecting Vargas’ proposed theory of defense jury instruction. Vargas argued that the jury should have been instructed that if RW’s injuries could be explained by a preexisting medical condition, the State had not met its burden of proof. The Supreme Court held that Vargas’ proposed instruction was not a proper theory of defense, as it essentially argued a failure of proof rather than presenting a recognized legal defense. The court affirmed the district court’s decision, concluding that the jury was adequately instructed on the State’s burden of proof and that Vargas was able to present his arguments during the trial. View "Vargas v. State" on Justia Law