Justia Wyoming Supreme Court Opinion Summaries

Bradley M. Schofield (Husband) and Debbie S. Schofield (Wife) were married in 1979 and separated in May 2016. In June 2021, Wife filed for divorce, and in September 2022, the district court entered a stipulated decree of divorce, which included a property distribution spreadsheet. The spreadsheet did not specify individual asset values but provided a total value for each party's distribution. Husband later filed a motion to enforce the decree, claiming Wife had not transferred an account valued at $185,300. Wife countered that the account had been transferred to Husband in 2016. The district court denied Husband's motion, finding he failed to prove the account had not been transferred.Husband did not appeal this decision but instead filed a W.R.C.P. 60(b) motion, claiming mutual mistake regarding the account's value in the decree. He argued that both parties misunderstood the $185,300 value. The district court denied this motion, ruling it was barred by res judicata, untimely, and not supported by evidence of mutual mistake.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision. The court held that Husband's claim of mutual mistake was actually a dispute over the interpretation of the decree, not a mutual mistake of fact. The court found no abuse of discretion in the district court's denial of the Rule 60(b) motion. Additionally, the court awarded Wife costs and attorney fees for defending the appeal, as allowed under Wyo. Stat. Ann. § 20-2-111. View "Schofield v. Schofield" on Justia Law

A father, involved in a custody dispute in Montana, subpoenaed his child's therapy records from a therapist in Wyoming. The therapist filed a motion to quash the subpoena, arguing that the records were privileged and confidential under Wyoming law and HIPAA, and that disclosing them would not be in the child's best interests. The district court in Park County partially granted the motion, allowing the father access to some records but withholding treatment notes, interviews, and process notes, citing the child's best interests.The district court's decision was based on the belief that protecting the child's best interests justified withholding certain records. However, Wyoming law does not recognize a child's best interests as a valid reason to deny a parent access to their child's therapy records if the parent has waived the privilege. The court did not provide any statutory or procedural basis for its decision, relying instead on a New Hampshire case, In re Berg, which is not binding in Wyoming and involved different legal standards.The Wyoming Supreme Court reviewed the case and found that the district court abused its discretion. The court held that Wyoming law, specifically W.R.C.P. 45 and Wyo. Stat. Ann. § 33-38-113, does not allow a court to quash a subpoena based on a child's best interests once the privilege has been waived by a parent. The court also clarified that HIPAA does not create a privilege that would prevent the disclosure of therapy records in judicial proceedings. Consequently, the Wyoming Supreme Court reversed the district court's decision and remanded the case, instructing the lower court to issue an order fully denying the therapist's motion to quash the subpoena. View "Loyning v. Potter" on Justia Law

Donald A. Whitmore was convicted of vehicular homicide and four misdemeanors following a car accident that resulted in the death of Antonio Jurado, III. The accident occurred after Whitmore and his coworkers completed an overnight shift and were traveling at high speed. The vehicle, driven by Whitmore, failed to navigate a curve, resulting in a crash that ejected Jurado, causing his immediate death. Whitmore and another passenger, Josh Voytoski, survived with injuries. Whitmore was found outside the vehicle, and both he and Voytoski initially claimed Jurado was driving. However, Voytoski later admitted Whitmore was the driver.The District Court of Converse County conducted a three-day jury trial where the central issue was whether Whitmore was driving. The jury found Whitmore guilty based on evidence including Voytoski’s testimony, forensic evidence, and Whitmore’s own statements. The court sentenced Whitmore to twelve to sixteen years for vehicular homicide and lesser concurrent sentences for the misdemeanors. Whitmore appealed, arguing prosecutorial misconduct during closing arguments.The Wyoming Supreme Court reviewed the appeal, focusing on whether the prosecutor’s comments during closing arguments constituted misconduct by commenting on Whitmore’s decision not to testify, shifting the burden of proof, or vouching for a witness’s credibility. The court found that the prosecutor’s statements did not directly or indirectly comment on Whitmore’s silence, improperly shift the burden of proof, or vouch for the credibility of Voytoski. The court held that the prosecutor’s comments were permissible inferences from the evidence presented.The Wyoming Supreme Court affirmed the lower court’s decision, concluding that Whitmore failed to demonstrate plain error or material prejudice from the prosecutor’s statements. The court emphasized the strength of the State’s case, including compelling circumstantial evidence that Whitmore was driving the vehicle at the time of the accident. View "Whitmore v. The State of Wyoming" on Justia Law

Jennifer Lynch pled guilty to one count of misdemeanor endangering children and one count of felony child abuse. She appealed her child abuse conviction, arguing that there was no factual basis to support the charge and that the district court abused its discretion in denying her post-sentence motion to withdraw her guilty plea.The District Court of Carbon County initially accepted Lynch's guilty plea after a colloquy to ensure it was made voluntarily. Lynch admitted to giving her prescription Seroquel to her mother, who then administered it to her children. The court found this sufficient to support the plea. Lynch was sentenced to nine-to-ten years in prison for child abuse and 25 days in jail for endangering children. She later filed a motion to withdraw her guilty plea, which the district court denied.The Supreme Court of Wyoming reviewed the case and found that the district court erred in accepting Lynch's guilty plea without a sufficient factual basis. The court noted that while Lynch admitted to giving Seroquel to her children, there was no evidence that this caused the physical injury required for a child abuse conviction under Wyoming law. The court emphasized that the factual basis must establish all elements of the charged crime, including physical injury, which was not demonstrated in this case.The Supreme Court of Wyoming reversed Lynch's child abuse conviction and remanded the case for further proceedings, finding that the district court's acceptance of the guilty plea without a sufficient factual basis materially prejudiced Lynch's substantial rights. View "Lynch v. The State of Wyoming" on Justia Law

In early fall 2021, JM, a student at Cody High School, disclosed to her counselor that her biological father, Dustin M. Sanchez, had inappropriately touched her during a visit in June 2021. JM reported that while watching a movie, Sanchez put his arm around her, reached across her chest, and placed his hand on her left breast under her shirt and bra. Despite her attempts to move away, Sanchez kept her close until she excused herself to go to the bathroom and texted her grandmother to pick her up. Sanchez was subsequently charged with one count of second-degree sexual abuse of a minor.The District Court of Park County conducted a three-day jury trial, resulting in Sanchez's conviction. He was sentenced to eight-to-ten years in prison. Sanchez appealed, arguing that the evidence was insufficient to sustain his conviction and that the prosecutor committed misconduct by misstating the law during closing and rebuttal arguments.The Wyoming Supreme Court reviewed the case. The court held that the evidence was sufficient to support Sanchez's conviction. The court noted that Sanchez, as JM's biological father, occupied a "position of authority" under Wyoming Statute § 6-2-315(a)(iv), which does not require additional proof of significant influence over the victim if the defendant falls into one of the statute’s enumerated categories, such as a parent. The court also found that the prosecutor did not misstate the law during closing arguments. The prosecutor's statements were consistent with the legal interpretation that Sanchez, as JM’s parent, inherently occupied a position of authority. Consequently, the court affirmed Sanchez's conviction and sentence. View "Sanchez v. The State of Wyoming" on Justia Law

Ming Zheng, a drilling field engineer, suffered a work-related injury to her right ankle while attempting to disassemble a tool string. She reported the injury and received workers' compensation benefits. Approximately a year later, Zheng sought additional benefits for an injury to her left ankle and requested preauthorization for surgery on her right ankle. The Wyoming Department of Workforce Services, Workers' Compensation Division, denied these requests, finding the treatments were not related to her original work injury. The Division also discontinued her temporary total disability benefits after she received a 0% impairment rating.The Wyoming Medical Commission upheld the Division's denial of benefits and discontinuation of temporary total disability benefits after a contested case hearing. The Commission found that Zheng failed to prove the requested treatments for her left ankle were related to her compensable work injury and that the surgery on her right ankle was necessary. The district court affirmed the Medical Commission's decision.The Wyoming Supreme Court reviewed the case and affirmed the lower court's decision. The Court held that substantial evidence supported the Medical Commission's findings that Zheng's left ankle issues were not related to her work injury and that the requested surgery on her right ankle was not necessary. The Court also found that the Medical Commission did not act arbitrarily or capriciously in admitting an addendum to Dr. Orth's independent medical evaluation, as Zheng had the opportunity to cross-examine Dr. Orth and present rebuttal evidence. The Court concluded that the Medical Commission's decision was supported by substantial evidence and was not arbitrary or capricious. View "Zheng v. State of Wyoming, Ex Rel. Department of Workforce Services" on Justia Law

Rick James Little was found guilty by a jury of one count of sexual abuse of a minor in the third degree and one misdemeanor count of attempted sexual battery. He filed a motion for a new trial, claiming ineffective assistance of counsel. The district court denied the motion, concluding that Mr. Little failed to show a reasonable probability that the outcome of the trial would have been more favorable absent any deficiencies in his counsel’s performance.The District Court of Campbell County initially reviewed the case. Mr. Little's defense argued that he was not present at the scene of the alleged crimes. However, during the trial, the prosecution presented strong evidence, including testimony from the victims and their mother, as well as a text message from Mr. Little that placed him at the scene. Mr. Little's counsel introduced his prior convictions during voir dire and opening statements, which Mr. Little later claimed was a strategic error. The district court found that the defense strategy, although unorthodox, was not unreasonable given Mr. Little's insistence on testifying.The Wyoming Supreme Court reviewed the case. The court held that Mr. Little did not demonstrate a reasonable probability that the trial outcome would have been different without the alleged deficiencies in his counsel’s performance. The court noted that the evidence against Mr. Little was strong, including detailed testimonies from the victims and corroborating evidence from their mother. The court also found that the potential alibi witness, Amber Everly, was equivocal about Mr. Little’s presence at her house on the night of the incident, and the text message evidence was dispositive. Consequently, the Wyoming Supreme Court affirmed the district court’s decision, concluding that Mr. Little was not denied effective assistance of counsel. View "Little v. The State of Wyoming" on Justia Law

A mother challenged the juvenile court's finding that she neglected her four-year-old child, RTB. The case began when the mother tested positive for methamphetamine, amphetamines, and marijuana during a medical appointment. Concerned for RTB's welfare, the healthcare provider reported the results to the Department of Family Services. A caseworker and a police officer visited the mother's home, where she again tested positive for the same substances. The officer took RTB into protective custody due to the mother's drug use and the lack of an appropriate caregiver in the home.The State filed a petition alleging neglect, and the juvenile court held a shelter care hearing, granting the Department legal custody of RTB. At a subsequent hearing, the court ordered RTB to be returned to the mother but retained legal custody with the Department pending an adjudicatory hearing. During the adjudicatory hearing, the State presented testimony from a Department supervisor, the police officer, and the mother, among others. The court found the mother neglected RTB and entered a written order to that effect.The Wyoming Supreme Court reviewed the case and affirmed the juvenile court's decision. The court held that the officer had reasonable grounds to take RTB into protective custody based on the mother's positive drug tests and the lack of a suitable caregiver. The court also found sufficient evidence to support the juvenile court's decision to place RTB in shelter care and to adjudicate the mother as neglectful. The evidence included the mother's repeated positive drug tests, her erratic behavior, and the unsafe environment in the home. The court concluded that the mother's actions constituted neglect as defined by Wyoming law. View "In the Interest of Minor Child v. The State of Wyoming" on Justia Law

Chadwick R. Traylor challenged the testamentary trust of his father, Donald R. Traylor, alleging undue influence by the defendants, who were beneficiaries under the trust. Traylor claimed that the defendants manipulated his father into amending the trust to their benefit. The district court, after a bench trial, denied Traylor’s claims and enforced the trust’s no-contest clause against him.The District Court of Natrona County initially set the case for a jury trial but later struck Traylor’s jury demand as untimely. Traylor argued that the demand was timely because not all defendants had answered, but the court disagreed, ruling that the time for serving the demand began when Traylor answered the defendants’ counterclaims. The court also denied Traylor’s subsequent motion for reconsideration and his request for a jury trial under W.R.C.P. 39(b), finding no extraordinary circumstances to justify such relief.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The Supreme Court held that Traylor waived his right to a jury trial by failing to timely serve his demand. The court also found no abuse of discretion in the district court’s denial of Traylor’s Rule 39(b) request for a jury trial. Additionally, the Supreme Court ruled that the district court applied the correct burden of proof, requiring Traylor to prove undue influence by a preponderance of the evidence, not by clear and convincing evidence. The court found that Traylor failed to meet this burden.The Supreme Court also upheld the district court’s enforcement of the no-contest clause against Traylor, interpreting the trust’s language to include him as a beneficiary subject to the clause. Finally, the Supreme Court found no abuse of discretion in the district court’s award of costs to the defendants, noting that Traylor did not provide an adequate record for review. The court affirmed the district court’s judgment in all respects. View "Traylor v. Green" on Justia Law

Donald and Mary Fuger own forty acres of land in Wyoming. Larry Wagoner began using a five-acre section of this land for his oilfield business around 2008. The Fugers and Wagoner agreed to construct two buildings on the site, with Wagoner handling construction and the Fugers securing financing. They did not formalize this agreement in writing. A lease agreement was signed, giving Wagoner exclusive use of the buildings for five years. Wagoner claimed there was an oral agreement to transfer ownership of one building and the land to him in exchange for his construction work and loan payments, which the Fugers denied.The District Court of Sweetwater County initially found in favor of Wagoner, awarding him damages for breach of the oral contract. However, the Wyoming Supreme Court reversed this decision in Fuger v. Wagoner, 2020 WY 154, ruling the oral contract void because Mrs. Fuger did not join the agreement. The case was remanded to consider Wagoner’s equitable claims. On remand, the district court found the Fugers were unjustly enriched by Wagoner’s construction work and awarded him damages, offsetting some of these due to his use of the buildings. The court also awarded prejudgment interest on a portion of the damages.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court held that the district court did not err in offsetting Wagoner’s damages by the actual rent he received rather than the fair rental value of the second building. The court also upheld the award of prejudgment interest, finding that a portion of Wagoner’s damages were liquidated and thus subject to such interest. The court concluded that the district court acted within its discretion in its equitable determinations regarding offset and prejudgment interest. View "Fuger v. Wagoner" on Justia Law