Justia Wyoming Supreme Court Opinion Summaries

In this case concerning the "beneficial owner" of Alderney Investments, LLC after Rudolf Skowronski, who controlled the company, disappeared, the Supreme Court affirmed the judgment of the district court entering judgment in favor of Edyta Skowronska, holding that sufficient evidence supported the jury's finding that Edyta and two of her minor children were ninety percent beneficial owners of Alderney.After Rudolf disappeared, conflicting purported transfers of interest in Alderney, a Wyoming limited liability company, led to disputes over the beneficial owner of the company. Management Nominees, Inc. (MNI-Belize) and Alderney (collectively, Appellants) claimed that Rudolf's brother-in-law was the beneficial owner and that MNI-Belize was its sole member. The jury reached a verdict in favor of Edyta, Rudolf's wife. The Supreme Court affirmed, holding (1) sufficient evidence supported the jury's conclusion that Edyta and two of her children were the beneficial owners of ninety percent of Alderney; (2) the district court did not err in declining to enter judgment as a matter of law that MNI-Belize is the sole member of Alderney; and (3) the district court did not err in declining to enter judgment as a matter of law that Edyta was disqualified from participating in Alderney's management. View "Management Nominees, Inc. v. Skowronska" on Justia Law

In this adverse possession case involving two cattle ranches the Supreme Court reversed the judgment of the district court granting summary judgment in favor of Plaintiffs, holding that genuine issues of material fact precluded summary judgment.Defendant owned a ranch that was historically known as Burnett Ranch. Plaintiffs were the most recent owners of Warbonnet Ranch. Plaintiffs filed a complaint for declaratory judgment and petition to quiet title with respect to three non-contiguous parcels of property that were deeded to Plaintiffs but fenced into Burnett Ranch. Defendant counterclaimed for adverse possession of those parcels. The district court granted summary judgment for Plaintiffs. The Supreme Court reversed, holding that genuine issues of material fact precluded entry of summary judgment in favor of Plaintiffs. View "Little Medicine Creek Ranch, Inc. v. D'elia" on Justia Law

The Supreme Court affirmed Defendant's aggregate sentence that left him eligible for parole after serving thirty-five years, holding that Defendant failed to show a constitutional violation or an abuse of discretion in the district court's sentencing decision.Defendant was convicted of one count of first-degree murder and twelve counts of aggravated assault and battery for crimes he committed at age sixteen. The district court sentenced Defendant to an aggregate prison term that left him eligible for parole after fifty-two years. The Supreme Court reversed the sentence and remanded for resentencing, holding that the sentence violated the Eighth Amendment because it was a de facto life without parole sentence. On remand, the district court imposed an aggregate sentence that left Defendant eligible for parole after serving thirty-five years. The Supreme Court affirmed, holding that Defendant's sentence did not violate the Eighth Amendment and that the district court did not abuse its discretion in sentencing Defendant. View "Sam v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of sexual assault in the third degree and intentional abuse of a vulnerable adult, holding that there was no error in the proceedings below.On appeal, Defendant argued that the district court erred when it admitted hearsay testimony of five witnesses and a video recording of the victim's Children Advocacy Project (CAP). Defendant also argued that the evidence was insufficient for the jury to convict him of the offenses. The Supreme Court affirmed, holding (1) neither the admission of the challenged testimony nor the CAP interview video violated a clear and unequivocal rule of law in a clear and obvious way, and in any event, Defendant failed to meet his burden of proving that he was materially prejudiced by admission of the evidence; and (2) the evidence was sufficient for the jury to convict Defendant of both sexual assault in the third degree and intentional abuse of a vulnerable adult. View "Brown v. State" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motions to withdraw his no contest plea to driving under the influence of alcohol, holding that Defendant's no contest plea was not knowing or voluntary, and therefore, the district court abused its discretion in denying Defendant's motions to withdraw his plea.On appeal, Defendant argued that his plea was not knowing or voluntary because the totality of the circumstances showed he did not fully understand the amended charge, the plea agreement, or the consequences of his plea. Further, Defendant claimed that he had insufficient time to speak with his attorney to discuss these matters prior to pleading guilty. The Supreme Court agreed, holding (1) under the specific circumstances of this case, Defendant's plea was not knowing or voluntary; and (2) the district court abused its discretion in not allowing Defendant to withdraw his no contest plea. View "Steffey v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of strangulation of a household member, holding that the district court did not err in admitting certain testimony and that the evidence was sufficient to establish the elements of strangulation.Defendant was convicted of strangulation and domestic battery for an incident in which Defendant's wife was found badly beaten. Defendant appealed only his strangulation conviction, arguing, among other things, that the district court erred in admitting the testimony of his wife's treatment physician for the truth of the matter asserted after ruling that the testimony would be admitted only for impeachment. The Supreme Court affirmed, holding (1) assuming that the district court's statement limiting the physician's testimony was in fact a ruling, Defendant failed to establish that the admission was prejudicial; and (2) the evidence was sufficient to support the jury's finding that Defendant caused bodily injury by impeding his wife's normal circulation of blood. View "Gonzalez-Chavarria v. State" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the judgment of the district court ordering Mother to reimburse funds she removed from the college account she managed for one of the parties' two children and awarding post-judgment interest, holding that the district court erred as a matter of law when it ordered payment of statutory post-judgment interest.In accordance with the divorce decree of Father and Mother, Father agreed to establish college accounts in the amount of $50,000 for each of the parties' two children. Mother managed one account, and Father managed the other account. The district court later ordered Mother to reimburse funds she removed from the account she managed. Mother appealed, arguing that the court abused its discretion in awarding damages in the amount of $50,000 and in awarded post-judgment interest. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err when it found damages in the amount of $50,000; and (2) the district court erred as a matter of law when it awarded ten percent post-judgment interest from September 2007. The court then remanded the matter for further proceedings on interest. View "Lew v. Lew" on Justia Law

The Supreme Court reversed Defendant's conviction of sexual assault in the first degree, holding that cumulative error resulting from prosecutorial misconduct deprived Defendant of a fair trial.On appeal, Defendant argued that the prosecutors committed numerous instances of misconduct during the state's case-in-chief and during the State's closing and rebuttal arguments. The Supreme Court remanded the case for a new trial, holding (1) the prosecutor violated the district court's Wyo. R. Evid. 404(b) order; (2) both prosecutors engaged in improper victim impact argument unrelated to credibility; (3) the prosecutor repeatedly argued facts that were not in evidence; (4) the prosecutor intentionally used inflammatory language in closing argument; and (5) cumulative error deprived Defendant of a fair trial. View "Bogard v. State" on Justia Law

The Supreme Court reversed the order of the probate court first granting Appellant's petition for probate of George W. Stanford's estate and appointment of an administrator but then reversing itself when the State objected to the appointment, holding that the State did not have standing to object to the appointment of the administrator.Appellant was incarcerated for more than twenty years when his convictions were vacated and an order of actual innocence was entered. Appellant later filed a complaint against the City of Cheyenne and several of its law enforcement officers, including Stanford, a detective who died before the complaint was filed. Appellant then filed a petition for the probate of Stanford's intestate estate and for appointment of an administrator. The probate court admitted the estate to probate and appointed an administrator. Thereafter, the State filed a document objecting to the appointment of an administrator for Stanford's estate. The probate court entered an order vacating the appointment of the administrator and closing the estate. The Supreme Court reversed, holding that the district court should have dismissed the State's objection for failure to state a claim because the State did not meet the probate code requirements for standing. View "Johnson v. State" on Justia Law

In this breach of contract case the Supreme Court affirmed the judgment of the district court denying Appellant's Wyo. R. Civ. P. 60(b) motion, holding that neither documents in a party's possession nor public records in existence at the time of trial are newly discovered evidence if, with due diligence, they could have been discovered prior to trial.In its rule 60(b) motion Appellant argued that two pieces of evidence - one of which it possessed and the other which was a matter of public record at the time of trial - constituted newly discovered evidence. The trial court denied the motion. Appellant appealed, arguing that it was not for a lack of due diligence that it did not discover the documents in its physical possession or data available on a website prior to trial. The Supreme Court disagreed, holding that the district court did not abuse its discretion in finding the evidence was not newly discovered because Appellant failed to exercise due diligence. View "SWC Production, Inc. v. Wold Energy Partners, LLC" on Justia Law