Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court terminating Mother’s rights to her three children, holding that the evidence clearly and convincingly established that Mother’s parental rights should be terminated.The district court found that the State presented clear and convincing evidence proving the statutory grounds for termination of Mother’s parental rights under both Wyo. Stat. Ann. 14-2-309(a)(iii) and (v). On appeal, Mother challenged the sufficiency of the evidence to establish the statutory requirements for termination of her parental rights. The Supreme Court affirmed, holding that the record supported the district court’s finding that each of the requirements for termination was proven by clear and convincing evidence. View "Swenson v. State, Department of Family Services" on Justia Law

The Supreme Court affirmed the decision of the Office of Administrative Hearings (OAH) to uphold the suspension of Appellant’s driver’s license, holding that collateral estoppel did not bar the OAH from considering Appellants’ blood alcohol content (BAC) test results in the license suspension proceeding.In the companion criminal case, the municipal court dismissed Appellant’s criminal charges without prejudice without referring to the prosecution’s argument that a gap in the chain of custody of Appellant’s blood samples rendered the BAC test results inadmissible. On appeal from the OAH proceedings, Appellant argued that the OAH was collaterally estopped from considering the BAC test results in the license suspension proceeding. The Supreme Court disagreed, holding that all four collateral estoppel requirements were not met under the circumstances. View "Casiano v. State ex rel. Wyoming Department of Transportation" on Justia Law

The Supreme Court affirmed the district court’s order terminating Mother’s parental rights to her two children, holding that there was clear and convincing evidence to support the jury’s finding that Mother’s parental rights should be terminated.During the termination proceedings, Mother admitted that her children were in foster care for more than fifteen of the most recent twenty-two months. The Supreme Court held (1) the State presented clear and convincing evidence that, at the time of the trial in this case, Mother was not able to meet her children’s physical, mental, or emotional needs; and (2) the State met its burden of proving that Mother was unfit to have custody or control of the children. View "Gillen v. State, Department of Family Services" on Justia Law

The Supreme Court affirmed the decision of the district court not to remove Lisa Kimsey as co-trustee of the Redland family’s irrevocable trust or to terminate the trust, holding that the district court did not err or abuse its discretion.Two of the three appeals consolidated in this decision related to Rolly Redland’s counterclaim to remove Kimsey as co-trustee for allegedly breaching her fiduciary duties and interfering with trust administration. The third appeal concerned Kimsey’s request to terminate the trust on the grounds that it was invalid and otherwise failed to achieve the settlers’ intended purposes. The district court decided not to remove Kimsey as co-trustee or terminate the trust. The Supreme Court affirmed, holding (1) res judicata barred Kimsey’s claim that the trust was invalid; (2) the district court did not err in finding that a material purpose of the trust remained; and (3) the district court did not err when it retained Kimsey as co-trustee of the trust. View "In re Robert and Irene Redland Family Trust" on Justia Law

The Supreme Court affirmed the district court’s order revoking Defendant’s probation and imposing the original suspended sentence, holding that the district court did not abuse its discretion by revoking Defendant’s probation.During the adjudicatory stage of proceedings the district court concluded that Defendant had failed to prove that he had complied the conditions of his probation and found that Defendant’s alleged violations were willful. The district court then revoked Defendant’s probation. The Supreme Court affirmed, holding (1) the scope of Defendant’s appellate waiver did not include his right to appeal from the order revoking his probation; and (2) the district court did not err in its conclusions, and the court’s findings were supported by the evidence. View "Bazzle v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court in favor of Sellers in this case involving a purchase of residential property, holding that the district court did not err in the proceedings below.After Buyers purchased residential property from Sellers, Buyers alleged that Sellers failed to comply with the requirement in the purchase contract that “Seller…complete a fully functional water well prior to closing” and thus breached the contract. The district court entered judgment in favor of Sellers. The Supreme Court affirmed, holding that the district court (1) did not err in ruling that Sellers completed a functional well by closing and thus did not breach the purchase contract; and (2) did not commit reversible error by excluding particular testimony or exhibits offered by Buyers. View "Schell v. Scallon" on Justia Law

In this family matter, the Supreme Court affirmed the district court’s order awarding Father primary physical custody and Mother visitation of the parties’ child, holding that the district court did not abuse its discretion when it refused to allow an undesignated witness to testify at trial.On appeal, Mother challenged the district court’s decision to preclude the witness’s testimony at trial as a sanction for Mother’s failure to designate that witness as an expert witness as required by the court’s scheduling order. The Supreme Court affirmed, holding that the district court did not err in deciding to exclude the witness’s testimony, and the sanction was not an abuse of discretion in this circumstance. View "McBride-Kramer v. Kramer" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s Wyo. R. Crim. P. 35(b) motion for sentence reduction, holding that there was no abuse of discretion.Defendant received a sentence of fourteen to eighteen years in prison in connection with his conviction of one count of aggravated vehicular homicide. After the district court denied Defendant’s motion for sentence reduction Defendant appealed. The Supreme Court affirmed, holding (1) the district court had a rational basis for denying Defendant’s motion for sentence reduction; and (2) Defendant’s argument that his sentence was illegal because it violated the Eighth Amendment prohibition against cruel and unusual punishment was procedurally barred. View "Barrowes v. State" on Justia Law

The Supreme Court reversed the district court’s grant of summary judgment in favor of the Jackson Hole Airport Board (Board) in this action brought by Wyoming Jet Center, LLC seeking access to certain records held by the Board, holding that the district court erred in ruling that the Board was not subject to the record disclosure requirements of the Wyoming Public Records Act (WPRA).In ruling in the Board’s favor, the district court concluded that the Special District Public Records and Meetings Act governed the Board’s record disclosure requirements, not the WPRA. The Supreme Court reversed, holding (1) the Special District Act defines neither the Board’s record retention requirements nor its disclosure requirements; and (2) the WPRA governed the Board’s public record disclosure requirements. View "Wyoming Jet Center, LLC v. Jackson Hole Airport Board" on Justia Law

The Supreme Court affirmed the decision Board of Equalization (Board) reversing the determination of the Department of Revenue (Department) that use of camp spots at the Johnson County Fairgrounds for use during the annual Johnson County Fair and Rodeo was subject to sales and lodging taxation, holding that the Board correctly determined that the campsites and rent received therefrom were not subject to taxation because the Johnson County Fair Board (Fair Board) was not a “vendor” as defined by Wyo. Stat. Ann. 39-15-101(a)(xv).For each of the campsites at issue, the County charged $25 per week and did not collect sales or lodging taxes. The Department concluded that the Fair Board was a non-exempt lodging vendor statutorily obligated to collect sales and lodging taxes for the campsite rentals. The Board reversed, concluding that the Fair Board was not a vendor and therefore not obligated to impose a tax on the fees charges for the use of the campsites. The Supreme Court affirmed, holding that the Board’s determination that the Fair Board was not a vendor and was therefore not required to impose an excise tax was supported by the record. View "State, Department of Revenue v. Board of County Commissioners of Johnson County" on Justia Law