Justia Wyoming Supreme Court Opinion Summaries

In this appeal from the juvenile court’s order on permanency hearing, the Supreme Court held that Father was not prejudiced by the juvenile court’s delay in appointing an attorney until shortly before the permanency hearing, and the juvenile court did not err in denying Father’s request for transport to the hearing.At issue on appeal was whether the juvenile court (1) violated Father’s due process rights when it did not advise him of his right to counsel and did not appoint an attorney until shortly before the permanency hearing, and (2) erred in denying Father’s request for transport to attend the hearing in person. The Supreme Court affirmed, holding (1) the juvenile court violated a clear rule of law when it failed to advise Father of his right to counsel at his first appearance in the proceeding and failed to act on Father’s initial request for appointment of counsel, but these errors did not materially prejudice Father; and (2) Father’s due process rights were not violated when the juvenile court denied Father’s request for transport to the permanency hearing. View "FH v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment to Defendants in this negligence action, holding that there were no genuine issues of material fact as to the issues on appeal.Skylar Dimick was injured when he fell into a septic tank on property owned by Scott Hopkinson. Dimick and his wife filed a negligence action against Hopkinson and his businesses, family trust, and wife, Chris Hopkinson. Plaintiffs sought punitive damages for Defendants’ alleged willful and wanton misconduct. The district court granted summary judgment to Defendants, concluding (1) Scott and his businesses were protected by a valid release of liability signed by Dimick, (2) Scott committed no willful and wanton acts, (3) Chris was neither a proximate cause of Dimick’s injuries nor engaged in a joint venture with Scott, and (4) the family trust did not exist. The Supreme Court affirmed, holding that the district court properly granted summary judgment as to all Defendants. View "Dimick v. Hopkinson" on Justia Law

The Supreme Court affirmed Defendant’s conviction for fraudulently altering a government record, holding that a printed copy of an unsigned an unfixed bond form qualifies as a government record, as defined by Wyo. Stat. Ann. 6-3-604(b).On appeal, Defendant argued that he did not violate section 6-3-604 because the bond order he altered was not a government record as defined by statute. Defendant also claimed that the State did not provide sufficient evidence to show that he acted with the specific intent required by section 6-3-604. The Supreme Court disagreed, holding (1) the bond order in this case was a government record; and (2) the State’s evidence was sufficient to show that Defendant had the requisite specific intent to act fraudulently - or to secure an advantage he was not entitled to - when he altered the document. View "Mathewson v. State" on Justia Law

The Supreme Court reversed the district court’s grant of summary judgment in favor of Pioneer Homestead on its professional negligence claim against Sargent Engineers, Inc. on the grounds that Pioneer’s claims were time-barred, holding that disputed issues of material fact existed with respect to whether Pioneer reasonably should have discovered Sargent’s alleged negligence.After Pioneer completed construction of an apartment building it discovered numerous design deficiencies in the building’s plans, as well as deviations from those plans in the building’s construction. Pioneer sued Sargent for professional negligence in the structural engineering services it provided during the design phase of the building’s construction. The district court ruled that Pioneer’s claims were time-barred as a matter of law. The Supreme Court reversed, holding that genuine issues of material fact existed as to when Pioneer should reasonably have been on notice that it needed to investigate the adequacy of the sign, plans, and specifications for the building. View "Pioneer Homestead Apartments III v. Sargent Engineers, Inc." on Justia Law

The Supreme Court affirmed Defendant’s conviction for felony possession of anabolic steroids found in a search of his vehicle.On appeal, Defendant challenged the denial of his motion to suppress the drugs found in his vehicle, arguing (1) the peace officer lacked probable cause to stop Defendant; (2) the peach officer lacked subsequent reasonable suspicion to detain; (3) the canine drug sniff while inside Defendant’s vehicle constituted an illegal search and seizure; and (4) the peace officer did not have additional probable cause to search absent the illegal dog sniff. The Supreme Court held that (1) because Appellant failed to present the district court with his arguments about probable cause for the stop or reasonable suspicion to continue his attention, these claims will not be considered on appeal; and (2) the circumstances established probable cause to search Defendant’s vehicle, even before the dog indicated there were drugs in the trunk. View "Pier v. State" on Justia Law

The Supreme Court affirmed the order of the district court holding Appellant in contempt for failing to comply with the parties’ divorce decree.On appeal, Appellant argued that the district court (1) violated principles of res judicata by receiving testimony in a contempt hearing on matters previously adjudicated at trial, and (2) abused its discretion when it found Appellant in contempt. The Supreme Court held (1) because Appellant failed to provide a record of the contempt hearing, the first issue will not be considered, and even if res judicata principles applied, Appellant’s argument was without merit; and (2) because no transcript of the hearing was provided, the Court must assume that the district court’s findings and rulings are correct, and thus they are summarily affirmed. View "Rigdon v. Rigdon" on Justia Law

The Supreme Court affirmed the decision of the district court affirming the decision of the Office of Administrative Hearings (OAH) concluding that the Wyoming Workers’ Compensation Division (Division) had properly terminated Appellant’s temporary total disability (TTD) benefits.The Division terminated Appellant’s TTD benefits after determining that Appellant had reached maximum medical improvement (MMI) and suffered an ascertainable loss. After a contested case hearing, the OAH concluded that the Division had properly ceased paying TTD benefits. The Supreme Court affirmed, holding that the OAH properly applied the relevant legal principals in reviewing the Division’s decision to terminate Appellant’s TTD benefits, and the OAH’s decision was supported by substantial evidence. View "Coggins v. State ex rel., Department of Workforce Services" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the district court’s judgment reversing the decision of the circuit court cancelling the mobile home sale between Respondent and Petitioner upon finding that the parties made a mutual mistake in drafting their contract, holding that the district court erred when it found that Petitioner breached the contract.Specifically, the Supreme Court affirmed the district court’s reversal of the circuit court’s finding of a mutual mistake of the parties, holding that the district court did not err in determining that the circuit court improperly applied the doctrine of mutual mistake. The Court, however, reversed the district court’s decision to hold Petitioner in breach of the contract before Respondent’s performance was due and, conversely, found that Respondent breached the contract, holding that the district court made a clearly erroneous finding of fact and as a matter of law. View "Larson v. Burton Construction, Inc." on Justia Law

In this employment dispute, the Supreme Court affirmed separate district court decisions holding that the International Association of Fire Fighters Local Union No. 5058 (IAFF Local 5058) and the International Association of Fire Fighters Local Union No. 5067 (IAFF Local 5067) were not properly constituted bargaining units under the Wyoming Collective Bargaining for Fire Fighters Act.IAFF Local 5058 and IAFF Local 5067 appealed from separate district court decisions governing their attempts to bargain collectively with their respective corporate entities. The district courts held (1) the Act’s definition of “fire fighters” included volunteers because they are “paid members of…regularly constituted fire department[s]”; and (2) IAFF Local 5058 and IAFF Local 5067, which were formed by and consisted of only full-time career fire fighters, were not entitled to be represented in collective bargaining negotiations. The Supreme Court affirmed, holding (1) the definition of “fire fighters” is unambiguous and includes volunteer and part-time (pool) fire fighters in Campbell and Teton counties; and (2) the context in these consolidated cases does not require a different interpretation. View "International Ass’n of Fire Fighters Local Union No. 5058 v. Gillette/Wright/Campbell County Fire Protection Joint Powers Board" on Justia Law

The Supreme Court affirmed the district court’s termination of Mother’s parental rights to her minor children, holding that Mother may not collaterally attack the juvenile court’s permanency order during prior neglect proceedings by appealing the district court’s termination of parental rights order.In 2014, the State filed a juvenile neglect action against Mother. In 2015, Mother admitted to the neglect allegations. While reunification was first recommended as the initial permanency goal, the permanency plan was later changed to termination of parental rights and adoption. The Department of Family Services then filed a civil action to terminate Mother’s parental rights. The district court terminated Mother’s parental rights after a bench trial. On appeal, Mother argued solely that the juvenile court violated her due process rights in the neglect proceedings. The Supreme Court affirmed, holding that Mother’s remedy was in juvenile court. View "Reed v. State, Department of Family Services" on Justia Law