Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed an order of the district court denying Appellant’s motion for sentence reduction, holding that the district court did not abuse its discretion when it denied Appellant’s motion for sentence reduction.Appellant, an addicted offender, failed on two separate occasions to complete treatment programs, resulting in his incarceration. While incarcerated, Appellant successfully completed treatment. Appellant moved for a reduction in sentence under Wyo. R. Crim. P. 35(b). The district court denied the motion. The Supreme Court affirmed, holding (1) the Addicted Offender Accountability Act does not require the release of an offender who completes treatment while incarcerated; and (2) the district court did not abuse its discretion or violate the AOAA when it denied Appellant’s motion for sentence reduction after he successfully completed various treatment programs during his incarceration. View "Cooper v. State" on Justia Law

The Supreme Court reversed Defendant’s conviction of fourth offense felony driving while under the influence (DWUI), holding that the district court erred, as a matter of law, when it concluded that the loopback for a fourth offense DWUI is to the date of the conviction and not to the date of the underlying offense.The State charged Defendant with felony DWUI in violation of Wyo. Stat. Ann. 31-5-233(b) and (e). The State based Defendant’s felony charge on his three prior convictions for DWUI within ten years of his most recent arrest. Defendant’s first offense did not occur within ten years of his fourth, but his conviction for the first for the first offense occurred within ten years of his fourth offense. Defendant appealed after pleading guilty to fourth offense felony DWUI. The Supreme Court reversed, holding that the felony enhancement loopback is to the offense and not the conviction. View "Rhoads v. State" on Justia Law

The Supreme Court affirmed the decision of the district court allowing the State to present testimony about an altercation Defendant had in jail while awaiting trial on charges of aggravated child abuse, holding that the district court abused its discretion in admitting the evidence but that Defendant was not prejudiced by the error.After a jury trial, Defendant was found guilty aggravated child abuse. Defendant appealed, arguing that the district court abused its discretion when it admitted evidence of the jail incident under Wyo. R. Evid. 404(b). The Supreme Court affirmed, holding (1) the admission of the evidence violated Rule 404(b); but (2) there was no reasonably probability that the verdict would have been different if the jail incident had not been admitted into evidence. View "Swett v. State" on Justia Law

The Supreme Court affirmed an order denying Appellant’s claim that his paintings were statutorily exempt from execution to satisfy a judgment debt, holding that the district court did not err in concluding that the paintings were not exempt from execution as “pictures” under Wyo. Stat. Ann. 1-20-106(a)(i).RADC/CADC Venture, LLC, which obtained a judgment against Appellant for nearly two million dollars, assigned its interest in the judgment to Radiance Capital Receivables Nineteen, LLC (Radiance). Radiance then applied for a writ of execution to be issued against Appellant’s real, personal and equitable assets located in Teton County. The Teton County Sheriff attached Appellant’s property, which included more than thirty works of art consisting primarily of paintings. On appeal, Appellant argued that his paintings were “pictures” that qualified for the exemption set forth in section 1-20-106(a)(i). The Supreme Court affirmed, holding that the term “pictures” in the statute did not extend to Appellant’s paintings. View "Crow v. 2010-1 RADC/CADC Venture, LLC" on Justia Law

The Supreme Court affirmed the decision of the district court denying Defendant’s motion to suppress her statements to highway patrol troopers and the marijuana they subsequently found in her car, holding that the record supported the district court’s finding that Defendant’s statements to the troopers were not coerced and the conclusion that the troopers did not violate Defendant’s due process rights.Defendant was the passenger in a car that was stopped for speeding. In response to questioning by the troopers, Defendant admitted to possessing medical marijuana that was located in the back of the car. After a search, the the troopers discovered marijuana. The Supreme Court affirmed, holding (1) the troopers’ detention and questioning of Defendant after the traffic stop was not unreasonable under the circumstances; and (2) Defendant gave her statements to the troopers voluntarily and and without coercion. View "Rodriguez v. State" on Justia Law

The Supreme Court reversed the judgment of the district court upholding the decision of the Department of Health for Medicaid, holding that the Department did not act in accordance with law when it denied Lucile Anderson’s application to have her sons’ payment of her attorney fees treated as a return of assets.The Department found Anderson eligible for nursing home benefits but suspended her eligibility as a penalty for her transfer of assets at below fair market value. Anderson’s sons paid the attorney fees and costs Anderson incurred in her unsuccessful appeal, and Anderson applied to have that payment treated as a return of assets, which would shorten the penalty period. The Department denied the application. The district court affirmed the Department’s decision. The Supreme Court reversed, holding that the Department erred in denying Anderson’s application because the Department’s Medicaid rules did not, as a matter of law, preclude the payment of Anderson’s attorney fees from being treated as a return of assets. View "Anderson v. State ex rel. Department of Health" on Justia Law

Defendant’s conviction of felony possession of marijuana, holding that Defendant did not demonstrate plain error when a supervisor from the state crime lab testified in place of the lab analyst who tested and weighed the marijuana.On appeal, Defendant argued that the State’s admission of the lab report containing the lab analyst’s conclusions violated his right to confrontation because the supervisor testified in place of the analyst. The Supreme Court affirmed without addressing the confrontation issues, holding that, even if the admission violated the confrontation clause, Defendant was not prejudiced. View "Lewis v. State" on Justia Law

The Supreme Court affirmed the orders of the district court granting summary judgment in favor of Defendants, three professionals, on Plaintiff’s claims of malpractice, breach of fiduciary duty, and conversion arising out of conservatorship and divorce proceedings, holding that the district court did not err.Defendants were Plaintiff’s conservator and counsel during the divorce proceedings. After the divorce concluded, Defendant filed this lawsuit alleging conversion, professional malpractice, and breach of fiduciary duty. The Supreme Court affirmed, holding (1) collateral estopped precluded Plaintiff from prevailing on his conversion claim; and (2) the district court did not err in granting summary judgment in favor of Defendants on the malpractice and breach of fiduciary duty claims. View "Tozzi v. Moffett" on Justia Law

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