Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court convicting Defendant of three counts of child endangerment and one count of possession of a controlled substance, holding that the district court did not violate Defendant's Fifth Amendment right to remain silent by admitting testimony regarding Defendant's contamination of a compelled urine sample.On appeal, Defendant argued that evidence of her contamination of the urine sample was admitted in violation of her right to remain silence because the contamination communicated her guilty knowledge or consciousness of guilt. The State raised the additional question of whether Defendant waived her Fifth Amendment claim when she failed to raise it in the district court. The Supreme Court affirmed, holding (1) Defendant had good cause for failing to raise her Fifth Amendment claim before trial so the claim was not waived; and (2) Defendant's decision to contaminate her sample was neither a communicative act nor an act compelled by the State, and therefore, evidence of Defendant's actions was not protected by the Fifth Amendment, and there was no plain error in the admission of the evidence. View "Herrera v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Office of Administrative Hearings (OAH) upholding the denial of Appellant's application to the Department of Workforce Services, Workers' Compensation Division for permanent partial disability (PPD) benefits, holding that the OAH's decision was not contrary to the overwhelming weight of the evidence.After Appellant injured his back the Division awarded him temporary benefits. When several years had passed without relief from his pain, Appellant appleid for PPD benefits. The Division denied Appellant's application. The OAH upheld the Division's denial of PPD benefits, concluding that Appellant failed to prove his work injury was the cause of his inability to return to employment and failed to prove that he timely filed his PPD application. The Supreme Court affirmed, holding (1) the OAH correctly calculated the limitations period under Wyo. Stat. Ann. 27-14-405(h)(ii); and (2) there was substantial evidence to support the OAH's conclusion that Appellant failed to prove that his injury was the cause of his inability to return to work. View "Camacho v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court reversed the order of the district court affirming the order of the Office of Administrative Hearings (OAH) upholding the Department of Workforce Services, Workers' Compensation Division's (Division) final determination regarding compensability, holding that the OAH erred in its determination that equitable estoppel did not bar the Division from asserting the statute of limitations as a defense.The OAH affirmed the final determination of the Division denying benefits to Appellant on the grounds that Appellant did not file a claim for benefits within the one-year statute of limitations set forth in Wyo. Stat. 27-14-503(a). The Supreme Court reversed, holding that the Division was estopped from asserting the statute of limitations as a defense, and therefore, the OAH's conclusion that section 27-14-503(a) barred Appellant's claim was not in accordance with law. View "Sweetalla v. State ex rev. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court reversed the judgment of the district court granting summary judgment in favor of the University of Wyoming (UW) and dismissing Plaintiff's declaratory judgment action, arguing that the district court abused its discretion in concluding that this declaratory judgment action challenging the legality of a UW regulation barring firearms on the UW campus served a useful purpose.Plaintiff was cited for misdemeanor criminal trespass after he refused to either relinquish his handgun, which he brought to a UW facility. Plaintiff pleaded not guilty in circuit court, obtained a stay of the criminal proceedings, and filed an action for declaratory judgment in district court, arguing that the regulation violated his constitutional right to bear arms. The district court granted summary judgment for UW. The Supreme Court reversed with instructions so that the matter may proceed in the circuit court, holding (1) Defendant had standing the challenge the legality of the regulation because of the pending criminal charge against him; and (2) the district court abused its discretion in concluding that this declaratory judgment action served a useful purpose. View "Williams v. State ex rel., University of Wyoming Board of Trustees" on Justia Law

The Supreme Court affirmed the decision of the Office of Administrative Hearings (OAH) denying Appellant's request for permanent partial disability benefits, holding that the OAH's decision was supported by substantial evidence and was not arbitrary or capricious.In denying Appellant permanent partial disability benefits the hearing examiner determined that Appellant had not established that because of his injury he was unable to return to employment at a wage of at least ninety-five percent of his monthly earnings at the time of his injury. On appeal, Appellant claimed that the hearing examiner should have found dispositive the undisputed fact that Appellant had applied for over fifty positions and still had no job. The Supreme Court affirmed, holding that the hearing examiner's decision was not contrary to the overwhelming weight of the evidence, and the district court did not err in affirming the hearing examiner's conclusion. View "Bollinger v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of Accessible Space, Inc. (ASI) and dismissing Plaintiffs' claim that ASI was negligent in failing to protect them from Larry Rosenberg's criminal action, holding that ASI did not have a common law duty to protect Plaintiffs from Rosenberg's unforeseeable criminal action.Appellants were living in a senior living apartment complex owned and operated by ASI when Rosenberg, a fellow tenant, shot them with a .22 caliber rifle. Appellants filed suit against ASI alleging negligence and asserting that ASI, as a landlord, had a duty to exercise reasonable care to protect them from Rosenberg's criminal action. The district court granted summary judgment in favor of ASI. The Supreme Court affirmed, holding (1) the district court did not err by concluding that ASI did not owe Plaintiffs a duty to protect them from Rosenberg's criminal action; and (2) even if ASI failed sufficiently to address Rosenberg's complaints, ASI's actions were not the proximate cause of Plaintiffs' injuries. View "Warwick v. Accessible Space, Inc." on Justia Law

The Supreme Court affirmed the district court's entry of a restitution order following an unconditional no contest plea to one count of exploitation of a vulnerable adult, holding that the district court did not act contrary to law in awarding restitution.Defendant pled no contest to one count of exploitation of a vulnerable adult. The district court sentenced Defendant to not less than eight nor more than ten years of incarceration, suspended in favor of ten years of probation. The court then awarded restitution of $532,890.80. Defendant appealed, challenging the award of restitution. The Supreme Court affirmed, holding that the district court reasonably awarded restitution in this matter. View "Freeman v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court, on a motion for judgment on the pleadings, resolving disputed questions of material fact concerning the propriety of Petitioner's proposed decanting of trust property, holding that the court properly concluded that Petitioner had the general authority to decant the trust property but erred in resolving disputed factual issues concerning the appropriateness of the proposed decanting.Petitioner, as trustee of a trust, filed a petition for instructions asking the district court to confirm its general authority to decant trust property under Wyoming law and the trust agreements and further sought approval of its proposal to decant the trust's property into two separate trusts. The district court granted Petitioner's motion for judgment on the pleadings, concluding that decanting was permissible. The court, however, also resolved disputed questions of material fact concerning the propriety of Petitioner's proposed decanting. The Supreme Court reversed in part, holding that the district court's order went beyond the discrete legal question of whether Petitioner had the general authority to decant trust property. View "Evertson v. Evertson Fiduciary Management Corp." on Justia Law

The Supreme Court affirmed the decision of the district court terminating Mother's parental rights to three of her minor children pursuant to Wyo. Stat. Ann. 14-2-309(a)(iii) and (v), holding that the evidence was sufficient to support the court's determination.While the district court found clear and convincing evidence supported termination of Mother's parental rights under both section 14-2-309(a)(iii) and (v) the Supreme Court needed determine only whether clear and convincing evidence supported one of the bases for termination. The Court affirmed the district court's finding of clear and convincing evidence to support termination under section 14-2-309(a)(v), holding that the district court's decision finding Mother unfit was supported by clear and convincing evidence. View "Dunlap v. State, Department of Family Services" on Justia Law

The Supreme Court reversed the order of the district court dismissing Appellant's divorce action against Appellee on the grounds of improper venue and/or forum non conveniens, holding that the district court erred by dismissing the action for improper venue and did not apply the correct test when it dismissed for forum non conveniens.The parties married in North Carolina in 1989. In 2018, Appellant filed a complaint for divorce in the district court in Fremont County, Wyoming, where he lived. Appellee filed a motion to dismiss the Wyoming action pursuant to Wyo. R. Civ. P. 12(b)(3), claiming that Wyoming was an improper venue for the divorce and/or forum non conveniens. The district court granted Appellee's motion. In doing so, the court followed the Supreme Court's decision in West Texas Utilities Co. v. Exxon Coal USA, Inc. 807 P.2d 932 (Wyo. 1991). The Supreme Court reversed, holding that the district court's analysis was inadequate. Consequently, the Court adopted the two-stage test for forum non conveniens from Gulf Oil Corp. v. Gilbert, 330 U.S. 501 (1947), and directed the district court to apply that test on remand. View "Saunders v. Saunders" on Justia Law