Justia Wyoming Supreme Court Opinion Summaries

Husband and Wife married in 2012 and purchased a home in Cheyenne, Wyoming, in 2014. They shared the residence and paid the mortgage from a joint account. In 2021, they refinanced the home, and in December 2021, they separated. They discussed the division of their marital property without attorneys and obtained two appraisals for the home. Wife retained counsel to draft a stipulated divorce decree, which both parties signed. The decree awarded the home to Husband, with a provision that Wife would receive half the net proceeds if the home was sold or refinanced.The District Court of Laramie County granted the divorce and entered the Stipulated Decree in June 2022. Husband refinanced the home but did not pay Wife her share of the equity. Wife filed a motion for relief, claiming the decree entitled her to half the equity regardless of whether the home was sold or refinanced. The district court granted Wife relief under Rule 60, correcting the decree to reflect that any equity recognized through sale or refinance was to be equally divided.Husband appealed, and the Wyoming Supreme Court found the decree ambiguous and remanded the case for an evidentiary hearing. The district court held a hearing and found that both parties intended to split the equity in the home equally. The court awarded Wife half the equity, amounting to $106,323.40, and Husband appealed again.The Wyoming Supreme Court affirmed the district court's decision, finding that the clarification under Rule 60(a) was appropriate and did not modify the original judgment. The court also found that the district court's findings of fact and conclusions of law were sufficient and supported by the record. View "Van Vlack v. Van Vlack" on Justia Law

Charles Leonhardt, a pretrial detainee at the Big Horn County Jail, suffered from back pain and was eventually diagnosed with two lower back infections after being transported to a hospital. He sued Big Horn County Sheriff Ken Blackburn, Jail Captain Debbie Cook, unnamed detention officers, the Big Horn County Sheriff’s Office, and the Jail, alleging negligence and deliberate indifference under the Fourteenth Amendment.The District Court of Big Horn County granted summary judgment to the defendants on both claims. The court found that Sheriff Blackburn had fulfilled his duty to arrange for medical care by contracting with Midway Medical Clinic, which provided medical services to inmates. The court also determined that the actions of Sheriff Blackburn, Captain Cook, and the detention officers were reasonable and did not proximately cause Mr. Leonhardt’s injuries. Additionally, the court found no evidence of deliberate indifference to Mr. Leonhardt’s medical needs, as the defendants ensured he received timely medical care.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decision. The court held that there was no genuine dispute of material fact regarding the negligence claim, as the defendants acted reasonably and provided Mr. Leonhardt with access to medical care. The court also found no evidence that the defendants were aware of and disregarded an excessive risk to Mr. Leonhardt’s health, thus failing to meet the subjective component of a deliberate indifference claim. Consequently, the court affirmed the summary judgment in favor of the defendants on both the negligence and Fourteenth Amendment deliberate indifference claims. View "Leonhardt v. Big Horn County Sheriff's Office" on Justia Law

Joseph W. Russell entered a conditional guilty plea to possession of methamphetamine, reserving his right to appeal the constitutionality of a warrantless search conducted as he entered the Uinta County Courthouse. The search, performed by Deputy Dan Jensen, involved a magnetometer alerting to metal in Russell's waist area, leading to a pat-down and the discovery of a snus can containing methamphetamine. Russell was charged with felony possession of a controlled substance.The district court denied Russell's motion to suppress the evidence, finding the search reasonable under the Fourth Amendment. Russell entered a conditional guilty plea, allowing him to appeal the suppression order. He was sentenced to one to three years of imprisonment, suspended in favor of two years of supervised probation. Russell timely appealed the denial of his motion to suppress.The Wyoming Supreme Court reviewed the case, focusing on whether the search violated the Fourth Amendment. The court applied a three-part test to determine the reasonableness of the search: the nature and immediacy of the governmental concern, the efficacy of the search in addressing that concern, and the nature of the privacy interest upon which the search intrudes. The court found that courthouse security is a compelling governmental interest, the use of a magnetometer and follow-up searches are effective in addressing this concern, and the privacy interest in the snus can was minimal given the context of courthouse security.The court concluded that the search was reasonable and affirmed the district court's denial of Russell's motion to suppress. The holding emphasized that the search was justified under the special needs exception to the Fourth Amendment, balancing the government's interest in courthouse security against the minimal intrusion on Russell's privacy. View "Russell v. State" on Justia Law

Matthew Justin Olson was convicted by a jury of conspiracy to commit first-degree murder. Olson was incarcerated in the Platte County Detention Center on federal charges and had pending state charges for domestic violence against his ex-wife, SK, who was a key witness. Olson asked his cellmate, Danny Hendershott, to kill SK in exchange for a government stimulus check. Hendershott initially agreed but later reported the plot to law enforcement, leading to an undercover operation by the ATF. Olson was subsequently charged with conspiracy to commit first-degree murder.The District Court of Uinta County allowed the State to introduce evidence under Rule 404(b) of the Wyoming Rules of Evidence, indicating Olson had other serious charges pending. Olson objected, arguing this evidence was prejudicial. The court limited the State to stating Olson had four serious charges pending and SK was an important witness. Olson was found guilty and sentenced to life imprisonment. He appealed, claiming the district court erred in its pretrial ruling on the admissibility of the 404(b) evidence.The Supreme Court of Wyoming reviewed the case and found that the word "serious" was never actually introduced during the trial. The State's evidence was limited to stating Olson had pending charges without categorizing them as serious. The court held that Olson's substantial rights were not affected by the district court's pretrial ruling since the evidence presented at trial was in line with what Olson deemed appropriate. Consequently, any potential error in the pretrial ruling was deemed harmless. The Supreme Court of Wyoming affirmed Olson's conviction. View "Olson v. State" on Justia Law

Appellee filed a complaint against Appellant alleging breach of written agreements for the lease of oil storage tanks. During the bench trial, the district court amended the complaint to include an oral guarantee to pay for the leases, which Appellant was not allowed to rebut. The court found Appellant breached the oral guarantee and awarded damages to Appellee.The District Court of Campbell County initially found in favor of Appellee, determining that Appellant breached the oral guarantee and awarded $114,537.56 in damages. Appellant raised multiple issues on appeal, including the admission of evidence, the application of the statute of frauds, and the effect of a settlement with a co-defendant.The Supreme Court of Wyoming reviewed the case and found that the district court did not abuse its discretion in admitting various exhibits into evidence. The court also held that the statute of frauds defense was waived as it was not raised at trial. Additionally, the court found that the settlement with the co-defendant did not preclude Appellee from pursuing claims against Appellant.However, the Supreme Court of Wyoming determined that the district court abused its discretion by not allowing Appellant to testify regarding the oral guarantee. The court affirmed the district court's rulings on the other issues but reversed and remanded the case for the limited purpose of allowing Appellant to testify about the oral guarantee. The remand is specifically for reconsideration of the personal guarantee and to provide both parties an opportunity to introduce evidence on that issue. View "Sorum v. Sikorski" on Justia Law

Everett Bray was convicted of felony stalking his ex-wife, MS, in violation of Wyoming Statute § 6-2-506(b)(iv) and (e)(iv). After being released from prison for a prior domestic violence offense against MS, Bray went to MS’s residence in June 2022, despite being warned by the sheriff’s department not to trespass. He threatened MS and her mother, leading to his arrest and a no-contact order. In January 2023, Bray returned to MS’s property, violating the protection order, and attempted to take her dog, resulting in another arrest.The District Court of Converse County sentenced Bray to 42-84 months in prison after a jury found him guilty of felony stalking. Bray appealed, arguing that the State presented insufficient evidence to prove he had the specific intent to harass MS.The Wyoming Supreme Court reviewed the case, applying the standard that assumes the State’s evidence is true and gives the State the benefit of every favorable inference. The court found that Bray’s actions, including his threats and repeated visits to MS’s property despite warnings and a protection order, demonstrated a continuity of purpose and intent to harass. The court held that a rational jury could find Bray’s conduct showed specific intent to harass MS, affirming the conviction. View "Bray v. The State of Wyoming" on Justia Law

Joseph Lyle Fredrick was charged with multiple counts of possession of controlled substances and misdemeanor theft in June 2021. He pled guilty to felony possession of marijuana and misdemeanor possession of heroin, leading to the dismissal of other charges. The district court sentenced him to 117 days for the misdemeanor, with credit for time served, and three to five years for the felony, suspended for three years of supervised probation. His probation was transferred to Oregon.In September 2023, the State filed a petition to revoke Fredrick’s probation, alleging he absconded and had no contact with his probation officer after July 2023. He was arrested in Oregon in November 2023, transported to Wyoming in December, and remained in custody. The district court held an initial appearance on December 19 and set an adjudication hearing for December 27. The State moved to allow the probation officer to testify by video, which the court granted. The hearing was continued to January 5, 2024, due to discovery issues and the probation officer’s failure to appear.At the January 5 hearing, the probation officer testified by video, and Fredrick moved to dismiss the revocation petition due to discovery violations. The court denied the motion but continued the hearing to January 19 to resolve the discovery dispute. On January 19, the court denied Fredrick’s motion to dismiss, found certain documents privileged, and concluded there was good cause for the continuances. The court revoked Fredrick’s probation and reinstated his three- to five-year sentence, with credit for time served.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court held that the district court did not abuse its discretion in extending the revocation hearing beyond the 15-day limit, allowing the probation officer to testify by video, and determining that certain probation records were privileged. The court also found that the discovery dispute did not warrant dismissal of the petition. View "Fredrick v. The State of Wyoming" on Justia Law

Marco Cardenas filed a negligence lawsuit against Rajean Fossen following a motor vehicle accident near Hudson, Wyoming. During the trial, Cardenas moved for judgment as a matter of law on Fossen’s liability, which the district court denied, allowing the jury to decide. The jury found Fossen was not negligent. Cardenas then renewed his motion for judgment as a matter of law and filed a motion for a new trial, both of which the district court denied. Cardenas appealed, arguing the district court should have granted his motion for judgment as a matter of law and remanded the case for a new trial on causation and damages.The district court of Fremont County initially granted Cardenas’s motion for summary judgment on Fossen’s affirmative defense of comparative fault but denied summary judgment on Fossen’s liability, citing a genuine issue of material fact. After a four-day jury trial, the jury found Fossen was not negligent. Cardenas’s post-trial motions for judgment as a matter of law and for a new trial were denied by the district court.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court held that Fossen’s statements during the trial did not constitute an unqualified admission of liability. The evidence presented allowed for more than one reasonable inference, and the jury could reasonably conclude that Fossen was not negligent. The court also found that the district court did not abuse its discretion in denying Cardenas’s motion for a new trial, as there was sufficient evidence to support the jury’s verdict. The Supreme Court affirmed the district court’s rulings, upholding the jury’s finding that Fossen was not negligent. View "Cardenas v. Fossen" on Justia Law

The case involves Wade Bloedow (Husband) and Nicole Maes-Bloedow (Wife), who married in 2017 and filed for divorce in 2022. The district court granted the divorce, divided the marital property, and ordered Husband to pay child support and temporary alimony. Husband appealed, arguing the district court abused its discretion in property distribution, income calculation for child support, and the award of temporary alimony. He also claimed the court failed to credit him for temporary payments made during the divorce proceedings.The District Court of Sweetwater County initially granted Wife temporary custody of the twins and ordered Husband to pay $3,000 per month in child and spousal support, plus the monthly payment on Wife’s vehicle. The court found Husband in contempt for not paying the full amount and allowed him to purge his contempt by selling marital assets and paying Wife from the proceeds. After a bench trial, the court awarded Wife most of the marital assets and assigned Husband most of the debts, citing his lack of credibility and fraudulent behavior in concealing and dissipating assets.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court found the district court acted within its discretion in determining the equity in the marital home and awarding Wife $75,000. It also upheld the overall property distribution, noting the district court considered the statutory factors and Husband’s fraudulent actions. The court found no abuse of discretion in the income calculation for child support, as the district court reasonably averaged Husband’s income from 2021 and 2022. The award of temporary alimony was also upheld, as the district court found Wife had a need for support and Husband had the ability to pay. Finally, the court affirmed the district court’s decision on past due support payments, finding the district court properly credited Husband for payments made during the divorce proceedings. View "Bloedow v. Maes-Bloedow" on Justia Law

In this case, Four Thirteen, LLC filed a complaint against three corporate entities and several individuals, including Joshua Wearmouth, Larry Stephens, Edmond X. Moriniere, Ronald G. Meyers, and David C. Norton. The complaint alleged that Wearmouth and Stephens solicited funds from Four Thirteen for a business venture involving Brazilian carbon credits, which turned out to be fraudulent. Four Thirteen claimed that the corporate entities did not own the carbon credits and that Wearmouth and Stephens made numerous misrepresentations. The complaint included claims of breach of contract, fraud, negligent misrepresentation, and other related allegations.The District Court of Laramie County reviewed the case and rejected the affidavits of non-involvement filed by Moriniere, Meyers, and Norton, who sought dismissal from the suit. The court found that there were factual issues regarding their involvement in the alleged fraud. Additionally, the district court imposed discovery sanctions and entered a default judgment against all defendants, including the individual appellants, for failing to comply with discovery orders.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision regarding the affidavits of non-involvement. The Supreme Court determined that the district court correctly found that there were factual disputes about the involvement of Moriniere, Meyers, and Norton, which precluded their dismissal from the case.However, the Supreme Court reversed the district court's decision to impose discovery sanctions against the individual appellants. The Supreme Court found that the appellants were not given proper notice that they were subject to sanctions under Wyoming Rule of Civil Procedure 37(b) and that there was no evidence they violated any prior discovery order. The court held that the sanctions against the individual appellants were not justified and remanded the case for further proceedings consistent with its opinion. View "Stephensv. Four Thirteen, LLC" on Justia Law