Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s conviction of strangulation of a household member, holding that Defendant failed to demonstrate that the State violated its obligations under Brady v. Maryland, 373 U.S. 83 (1963).On appeal, Defendant argued that his due process rights were violated when the State failed to comply with Brady by withholding evidence from him until the last possible moment before trial. The Supreme Court disagreed, holding that the State did not violate Brady by providing the evidence to Defendant within the deadline established by the district court. View "Curby v. State" on Justia Law

The Supreme Court affirmed a district court order revoking Appellant’s probation and ordering that he serve the remaining portions of a prison sentence that had been suspended, holding that Appellant’s underlying sentence was not illegal.Appellant pleaded guilty to state charges and was later convicted of federal charges arising from the same conduct that resulted in the state charges. After Appellant was sentenced to a “lengthy” prison sentence, Appellant and the State filed a stipulated motion requesting the court to modify the order granting a sentence reduction. The district court granted the motion and modified Appellant’s sentence in accordance with the motion. When Appellant was released from federal prison and began to serve his state probation, the district court determined that Appellant had violated terms of his probation and revoked his probation. On appeal, Appellant argued that the reduced sentence he requested and the district court ordered was illegal. The Supreme Court affirmed, holding that Appellant’s modified reduced state sentence did not consist of impermissible interrupted periods of incarceration, and therefore, Appellant’s sentence was not illegal. View "Nitchman v. State" on Justia Law

The Supreme Court affirmed a district court order revoking Appellant’s probation and imposing underlying sentences for her child endangerment and controlled substance convictions, holding that the district court did not abuse its discretion.Specifically, the Court held that the district court (1) did not abuse its discretion by relying on hearsay and non-hearsay evidence to find that Appellant violated a condition of her probation on two occasions; (2) did not abuse its discretion in finding that Appellant violated a probation condition by failing to submit to a scheduled urinalysis appointment; and (3) did not err in determining that Appellant willfully violated a probation condition requiring her to report for a urinalysis test. View "Brumme v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the district court’s dismissal of Plaintiff’s complaint alleging negligence and violations of 42 U.S.C. 1983 after Linda Gelok was injured after being left unattended for twenty-five hours at the Wyoming State Hospital (WSH), holding that the complaint alleged sufficient facts to state a claim for relief under 42 U.S. C. 1983 against Paul Mullenax, WSH Administrator, in his individual capacity.On behalf of Linda Gelok, an involuntarily committed incompetent person, Plaintiff sued the WSH, the Wyoming Department of Health, and Mullenax, WSH Administrator, in his official and individual capacities, alleging negligence and violation of her constitutional rights under 42 U.S.C. 1983. The district court dismissed the negligence action as time-barred. As to the constitutional claims, the district court found that the WSH, the Department, and Mullenax in his official capacity were entitled to Eleventh Amendment immunity and that Mullenax was entitled to qualified immunity in his individual capacity. The Supreme Court held (1) Wyo. Stat. Ann. 1-3-107 barred Plaintiff’s negligent health care claim; (2) the district court properly dismissed Plaintiff’s 42 U.S.C. 1983 claims against most defendants; but (3) Plaintiff’s complaint alleged sufficient facts to state a claim for relief under 42 U.S.C. 1983 against Mullenax in his individual capacity. View "Wyoming Guardianship Corp. v. Wyoming State Hospital" on Justia Law

The Supreme Court affirmed Defendant’s conviction of second degree sexual assault, holding that the trial court erred in admitting evidence of prior bad acts absent notice from the State of its intent to offer such evidence and without conducting a hearing pursuant to Gleason v. State, 57 P.3d 332 (Wyo. 2002), but the error did not prejudice Defendant.The State in this case failed to disclose its intent to use Wyo. R. Evid. 404(b) evidence and failed to provide the purpose for admission of such evidence prior to trial, and the State’s omissions prevented the district court from holding the required Gleason hearing prior to admission of the evidence. The Supreme Court held (1) the evidence falling within the purview of Rule 404(b) was erroneously admitted, without the required Gleason analysis; but (2) there was no reasonable possibility the verdict would have been different without the evidence, and therefore, the error was not prejudicial. View "Broberg v. State" on Justia Law

The Supreme Court affirmed the district court’s decision ruling generally in favor of Judy Weeks-Rohner in this quiet title action brought by the Estate of Jack Winford Weeks, holding that there was no error or abuse of discretion.When Jack Weeks and Judy Weeks-Rohner divorced, the divorce decree directed that their jointly owned home would remain in Weeks’ possession, subject to a trust for their minor son. The trust, however, was never formed. After the son and then Weeks died, the Estate of Jack Weeks filed a quiet title action against Weeks-Rohner, asserting adverse possession of the property. Weeks-Rohner counterclaimed, requesting that the court enforce the divorce decree by quieting title to the property in the deceased son and/or his heirs. The district court ruled generally in favor of Weeks-Rohner. The Supreme Court affirmed, holding (1) the district court did not err in quieting title to the property in both parties with each owning an undivided one-half interest as tenants in common; (2) there was no error in the district court’s rejection of the Estate’s adverse possession claim; and (3) the court was within its inherent authority when it enforced its decree by ordering the parties to place the property in a trust for the deceased son. View "Estate of Jack Winford Weeks v. Weeks-Rohner" on Justia Law

The Supreme Court affirmed the jury verdict awarding Basic Properties, Inc. $200,000 in damages for Essex Holding, LLC’s refusal to consent to amend restrictive covenants to allow Basic to develop one of its lots in a shopping center. The Court held (1) Essex timely filed its notice of appeal; (2) Basic had standing to assert its counterclaim; (3) the district court did not err when its submitted Basic’a counterclaim for breach of contract to the jury; (4) the jury instructions rejecting Essex’s theory regarding a void amendment did not constitute plain error; (5) cumulative error did not result in an excess verdict or a verdict contrary to law; (6) the district court properly granted basic’s motion for judgment as a matter of law on Essex’s anticipatory repudiation claim; (7) the district court did not err in its award of attorney fees and costs to Basic; and (8) the district court properly denied Essex’s Wyo. R. Civ. P. 60(b) motion. View "Essex Holding, LLC v. Basic Properties, Inc." on Justia Law

Appellant Steven Mitchell was held in contempt of court for violating a custody order. The district court ordered confinement until Mitchell purged himself of contempt by relinquishing custody of the minor child. While confined for contempt, Mitchell pled no contest to one count of felony interference with custody, for which he received a sentence of three and one-half years to five years of imprisonment, with no credit for presentence incarceration. The district court also ordered the criminal sentence to commence on termination of Mitchell’s confinement for contempt. Mitchell appeals his criminal sentence contending it was illegal. Finding no reversible error or illegality, the Wyoming Supreme Court affirmed. View "Mitchell v. Wyoming" on Justia Law

The Supreme Court dismissed for lack of jurisdiction the appeal brought in the name of Mother challenging the district court’s imposition of sanctions against Mother’s attorney, Traci Mears, holding that Mother did not have standing to pursue an appeal on behalf of Mears and that Mears failed to file a timely notice of appeal challenging the order.Mother engaged Mears to initiate adoption proceedings so that Mother’s husband could adopt the child she had with Father. Father and Mother agreed that Father would consent to the adoption and, in return, Mother would waive all child support and related arrearages. Ultimately, the district court found that Father performed his obligations pursuant to the agreement, that Mother failed to perform her obligations, and that Father incurred unnecessary attorney’s fees as a result. The court then entered an order enforcing the settlement agreement and ordered Mears to pay for Father’s attorney’s fees under Wyo. R. Civ. P. 11. Mother appealed on behalf of Mears challenging the imposition of sanctions. The Supreme Court dismissed the appeal, holding that the Court lacked subject matter jurisdiction to hear the appeal because Mears failed to file a timely notice of appeal in her own name. View "In re Order Imposing Sanctions on Traci E. Mears" on Justia Law

The Supreme Court reversed the order of the district court denying Father’s petition to modify the order granting Mother primary custody of the parties' children, holding that the district court abused its discretion by determining that Father had demonstrated a material change in circumstances to justify re-opening the governing custody and visitation order.The district court concluded that Father had not established a material change in circumstances because there was little to no evidence that the children’s welfare was affected by Mother’s alleged instability in her life and poor decision-making. The Supreme Court remanded this case to the district court to determine whether modification of the custody and visitation order was in the best interests of the parties’ two daughters, holding (1) a court need not wait until the children exhibit negative consequences before reconsidering custody and/or visitation; and (2) where there was significant evidence of Mother’s continued instability and poor decision-making and the parties’ inability to make the current custody/visitation arrangement work, there was a material change of circumstances. View "Jacobson v. Kidd" on Justia Law