Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s conviction of first-degree felony murder and sentence of life imprisonment, holding that Defendant failed to demonstrate plain error in testimony elicited from medical experts concerning a diagnosis that has a distinct legal meaning.On appeal, Defendant argued that the State’s medical experts offered improper testimony as to Defendant’s guilt or credibility. The Supreme Court disagreed, holding (1) the district court did not err in permitting the challenged testimony because the diagnoses contained terms with distinct legal meanings that did not equate to expressing an opinion as to Defendant’s guilt; (2) Defendant did not demonstrate plain error in testimony elicited from medical experts concerning inconsistencies between Defendant’s proposed mechanism of injury and their observations of the victim’s injuries; and (3) Defendant did not demonstrate plain error in the State’s cross-examination of a certified forensic pathologist. View "Nielsen v. State" on Justia Law

The Supreme Court affirmed the order of the district court affirming the decision of the Wyoming State Board of Equalization (state) reversing the decision of the Washakie County Board of Equalization (county board) reversing the valuations of the Washakie County Assessor classifying Taxpayers’ four properties as either residential or vacant residential for tax purposes, holding that Taxpayers’ property did not qualify for classification as agricultural lands.Taxpayers separately owned four parcels of land in Washakie County, Wyoming. In March 2014, the Assessor issued notices of assessment for Taxpayers’ properties classifying the parcels as either residential or residential vacant. The county board reversed the valuations, concluding that Taxpayers had demonstrated that their properties met the four requirements under Wyo. Stat. Ann. 39-13-103(b)(x)(B) to be taxed as agricultural land. The state board reversed. The district court affirmed. The Supreme Court affirmed, holding that Taxpayers failed to meet their burden to overcome the presumption in favor of the Assessor’s assessments. View "Helmut v. Mueller Limited Partnership v. Treanor" on Justia Law

The Supreme Court reversed the decision of the district court reversing the decision of the Office of Administrative Hearings (OAH) reversing the decision of the Wyoming Department of Family Services (DFS) terminating Appellant’s position as a fraud investigator, holding that the OAH’s determination that DFS lacked good cause for dismissing Appellant was supported by substantial evidence and complied with the law.DFS dismissed Appellant when it discovered that she signed daycare logs for her grandchildren that resulted in overpayment of DFS child care benefits to daycare providers in the amount of $196.95. The OAH reversed, concluding that DFS lacked good cause for dismissing Appellant. The district court reversed. The Supreme Court reversed the district court’s judgment and reinstated the OAH’s decision, holding the OAH’s determination was supported by substantial evidence and in accordance with the law. View "Lietz v. State ex rel. Department of Family Services" on Justia Law

The Supreme Court affirmed the orders of the Office of Administrative Hearings (OAH) granting summary judgment to Air Methods/Rocky Mountain Holdings, LLC, EagleMed, LLC, and Med-Trans Corp. (collectively, Claimants) and ruling that the Wyoming Workers’ Compensation Division (Division) was required to pay the full amount billed by Claimants, holding that Wyo. Stat. Ann. 27-14-401(e), as severed, required the Division to pay Claimants the full amount of their billing for air ambulance services.Claimants, who operated air ambulance services in Wyoming, filed separate claims with the Division for services they provided to injured workers. The Division paid only the amounts permitted by its fee schedule, which were significantly less than the amounts billed. Claimants appealed. The OAH ruled (1) in accordance with a federal ruling that the Airline Deregulation Act of 1978 (ADA) preempted the Division’s air ambulance fee schedule, the Division was required to pay the full amount billed by Claimants; and (2) Air Methods was not entitled to pre- or post-judgment interest on its claims. The Supreme Court affirmed, holding that the OAH correctly ruled (1) section 27-14-401(e) was severable and, as severed, required Claimants to be paid the full amount they sought; and (2) it lacked statutory authority to award interest on the contested claims. View "Air Methods/Rocky Mountain Holdings, LLC v. State ex rel. Department of Workforce Services" on Justia Law

The Supreme Court reversed the order of the Wyoming Board of Equalization (Board) concluding that the issue disputed by the parties in this case was moot, holding that the Board exceeded its authority when it decided an issue that was not before it.Solvay Chemicals, Inc. appealed to the Board the Department of Revenue’s (DOR) assessment of the taxable value of soda ash produced at its trona mine in Sweetwater County, disputing the calculations the DOR used to determine the amount of the deduction for bagging some of the soda. After a contested case hearing, the Board requested supplemental briefs to address a question of statutory construction that had not been raised by either party. The Board then decided that the issue was whether Solvay was entitled to any bagging deduction at all. The Board ultimately concluded that because the governing statute did not allow for a separate deduction for bagging the issue was moot. The Supreme Court reversed, holding that the Board exceeded its authority when it based its order on an issue not contested or addressed by either party during the contested case hearing. View "Solvay Chemicals, Inc. v. State Department of Revenue" on Justia Law

In this custody dispute, the Supreme Court reversed the order of the district court imposing a visitation schedule that required extensive travel between Mother’s residence in Wyoming and Father’s residence in Arizona and requiring Father to pay child support below the presumptive statutory amount, holding that the district court abused its discretion in failing adequately to consider the best interests of the child in setting forth the visitation schedule and abused its discretion in fixing Father’s child support obligation.The district court awarded primary physical custody of the child to Mother and established a visitation schedule requiring the child to travel between Wyoming and Arizona until the child reaches school-age, at which time the parties must agree on a new visitation schedule or seek modification. The court also deviated downward from statutory child support guidelines without stating the presumptive child support amount. The Supreme Court reversed, holding that the district court (1) abused its discretion in failing adequately to consider the best interests of the child when it imposed a graduated visitation plan requiring extensive travel that did not specify how visitation would work when the child started kindergarten; and (2) must obtain and consider additional evidence to support any deviation in child support in order to comply with Wyo. Stat. Ann. 20-2-307(b). View "Martin v. Hart" on Justia Law

The Supreme Court affirmed Defendant’s conviction of two counts of second degree sexual assault by a person in a position of authority, in violation of Wyo. Stat. Ann. 6-2-303(a)(vi), holding that Defendant’s no-contest pleas waived the issue he raised on appeal.Defendant pleaded no contest to two charges of second degree sexual assault. On appeal, Defendant argued that the facts alleged in this case did not constitute a crime because a clinical psychologist is not in a position of authority as that term is used in the applicable Wyoming criminal statute. The Supreme court affirmed the convictions and judgment of the district court, holding that, by pleading no contest, Defendant waived the right to challenge all the issues he raised on appeal. View "Popkin v. State" on Justia Law

The Supreme Court affirmed convictions of Defendants - Dennis Larkins and Emily Larkins - for multiple counts of child abuse and one count of abuse of a vulnerable adult, holding that there was no reversible error in the proceedings below.Specifically, the Court held (1) the State presented sufficient evidence to support the convictions; (2) the district court did not err when it denied Defendants’ motion for new trial based on ineffective assistance of counsel; and (3) while some of the prosecutor’s statements during closing argument amounted to misconduct, the misconduct did not materially prejudice either Defendant. View "Larkins v. State" on Justia Law

The Supreme Court affirmed the juvenile court’s order changing the permanency plan for the Child from family reunification to adoption, holding that Father’s challenges on appeal were unavailing.Specifically, the Court held (1) the district court did not violate Father’s right to due process when it held the permanency hearing without securing his attendance or testimony, took judicial notice of the juvenile case file, and allowed the State to present information about the case by offer of proof rather than sworn witness testimony; and (2) the juvenile court did not abuse its discretion when it determined that the Department of Family Services made sufficient efforts to reunify the Child with Father and that it was in the Child’s best interest to change the permanency plan from reunification to adoption. View "GS v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions for strangulation of a household member and domestic battery, holding that Defendant failed to demonstrate plain error on appeal.Specifically, the Court held (1) the district court did not commit plain error in allowing the State to present evidence that may be construed as victim impact testimony in its relevance; (2) the district court did not commit plain error in allowing a witness to testify as to what Defendant argued was her opinion that Defendant was guilty because the testimony did not contain an actual conclusion of Defendant’s guilt; and (3) as to Defendant’s argument that certain testimony improperly vouched for the credibility of the victim, there was no reasonable probability that the jury would have returned a more favorable verdict in the absence of the disputed testimony. View "Dumas v. State" on Justia Law