Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s convictions for aggravated assault and battery and breach of peace, thus rejecting Defendant’s claims of error on appeal.Specifically, the Court held (1) the district court properly instructed the jury regarding the definition of “threatened to use” as defined in Wyoming law; (2) the district court abused its discretion when it admitted uncharged misconduct evidence at trial without first conducting a Gleason analysis, but the error was harmless; and (3) the State presented sufficient evidence to support Defendant’s aggravated assault and battery conviction by presenting evidence that Defendant “threatened to use a drawn deadly weapon” against Gordon Johnson. View "Birch v. State" on Justia Law

Plaintiff violated its duty under Wyo. R. Civ. P. 26 to provide its computation of damages and the documents supporting its damages claim to Defendant, and therefore, the district court abused its discretion by admitting Plaintiff’s damages evidence at trial.Plaintiff filed suit claiming that Defendant and his daughter improperly interfered with a business relationship of Plaintiff. The district court granted judgment in favor of Plaintiff. The Supreme Court reversed and directed that judgment be entered in favor of Defendant on Plaintiff’s claims, holding that the district court’s finding that Plaintiff had suffered $25,000 per month for ten months in damages was clearly erroneous. View "Downs v. Homax Oil Sales, Inc." on Justia Law

The Supreme Court affirmed the district court’s judgment and sentence entered after Defendant pleaded guilty to one count of intentionally exploiting a vulnerable adult, holding that the district court did not err when it held that the State had met its burden of proving the amount of restitution.The district court ordered Defendant to pay $43,821.30 in restitution to the man whose resources Defendant depleted, eighty-nine-year-old Wallace Reaves. The Supreme Court upheld the award of restitution, holding that the evidence provided a reasonable basis for calculating the amount of restitution, and therefore, there was sufficient evidence to support the district court’s findings. View "Voelker v. State" on Justia Law

The Supreme Court affirmed the district court’s dismissal of Plaintiff’s complaint against Defendant asserting claims for defamation per se and injunctive relief, although on grounds different from those expressed by the district court.Plaintiff filed her claims against Defendant after Defendant made statements critical of Plaintiff’s performance as Superintendent of Public Instruction. The district court concluded that Defendant’s statements implicated First Amendment concerns and dismissed the complaint for failure to allege facts sufficient to support the constitutionally-required showing of actual malice. The Supreme Court affirmed, albeit on different grounds, holding (1) the district court properly found that Plaintiff was a public official for First Amendment purposes; (2) the complaint stated facts sufficient to support a claim for actual malice; but (3) the complaint failed to allege facts sufficient to state a claim for defamation per se, and on that ground, the Supreme Court upheld the district court’s dismissal. View "Hill v. Stubson" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of eight felonies and holding that Defendant had failed to prove that he was not guilty by reason of mental illness or defect.Defendant was charged with eight felonies, including aggravated assault and battery, aggravated robbery, and theft. Defendant pleaded not guilty and not guilty by reason of mental illness or defect (NGMI). After a bench trial the court found Defendant guilty on all eight counts. On appeal, Defendant argued that the district court erred in concluding that he failed to prove he was not guilty by reason of mental illness. The Supreme Court affirmed, holding (1) the applicable standard of review is whether, after reviewing the evidence in the light most favorable to the State, a rational trier of fact could have found that the defendant failed to prove the defense by a preponderance of the evidence; and (2) under this standard, Appellant failed to prove the NGMI defense by a preponderance of the evidence. View "Gabbert v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of eight felonies and holding that Defendant had failed to prove that he was not guilty by reason of mental illness or defect.Defendant was charged with eight felonies, including aggravated assault and battery, aggravated robbery, and theft. Defendant pleaded not guilty and not guilty by reason of mental illness or defect (NGMI). After a bench trial the court found Defendant guilty on all eight counts. On appeal, Defendant argued that the district court erred in concluding that he failed to prove he was not guilty by reason of mental illness. The Supreme Court affirmed, holding (1) the applicable standard of review is whether, after reviewing the evidence in the light most favorable to the State, a rational trier of fact could have found that the defendant failed to prove the defense by a preponderance of the evidence; and (2) under this standard, Appellant failed to prove the NGMI defense by a preponderance of the evidence. View "Gabbert v. State" on Justia Law

The Supreme Court affirmed the decision of the district court quieting title on the mineral rights in lands conveyed by two deeds in 1913 in Box Creek Mineral Limited Partnership.Box Creek brought this action against BNSF Railway Company seeking to quiet title in the mineral rights at issue. The parties disputed whether the 1913 deeds passed a fee simple estate from Box Creek to BNSF, thereby conveying the underlying mineral estate, or if the deeds merely conveyed an easement in fee simple, whereby the minerals would not pass to BNSF. The district court concluded that the deeds were ambiguous and that the parties intended an easement-like conveyance rather than a fee simple interest and quieted title to the mineral estate in Box Creek. The Supreme Court affirmed, holding (1) the district court correctly concluded that the parties intended a limited grant from Box Creek to BNSF, in what amounted to an “easement-like conveyance"; and (2) the district court properly admitted the testimony of Marc Strahn as expert witness testimony. View "BNSF Railway Co. v. Box Creek Mineral Limited Partnership" on Justia Law

The Supreme Court vacated certain portions of the order of the district court fixing restitution after Defendant pleaded no contest to obtaining welfare benefits by misrepresentation.Following Defendant’s no-contest plea, the district court fixed restitution at $18,733. Defendant filed a motion requesting that the district court find she was unable to pay the restitution. After a hearing, the district court issued an order that fixed the amount of Defendant’s restitution at $18,733 but did not require Defendant to pay it, finding that she lacked the ability to do so. Nevertheless, the district court allowed the State to reduce $18,733 to a civil judgment. The Supreme Court held (1) because the district court did not order restitution, it erred as a matter of law when it allowed the State to reduce $18,733 to a civil judgment; and (2) the district court erred as a matter of law by failing either to order restitution or specifically find that there exists no reasonable probability that Defendant will be able to pay restitution in the future. View "McEwan v. State" on Justia Law

The Supreme Court reversed Appellant’s second conviction for kidnapping and affirmed his remaining convictions, holding that Appellant’s convictions and sentences for two counts of kidnapping violate double jeopardy.Appellant was convicted of strangulation of a household member, domestic battery, and two counts of kidnapping. The convictions arose from a single violent episode involving Appellant’s girlfriend. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not abuse its discretion in allowing the State to introduce evidence of uncharged misconduct; (2) the two convictions for kidnapping violated Appellant’s protections against double jeopardy because Appellant’s actions supported only one continuing kidnapping offense; and (3) the separate convictions for domestic battery and strangulation of a household member did not violate Appellant’s protections against double jeopardy because Appellant did not satisfy his burden to prove that the two convictions were based on the same incident. View "Volpi v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant, after a jury trial, of conspiracy to commit aggravated burglary, conspiracy to commit aggravated robbery, conspiracy to commit aggravated assault and battery, and conspiracy to commit theft.On appeal, Defendant argued that the State failed to present sufficient evidence to support three of his convictions. The Supreme Court disagreed, holding that there was insufficient evidence to support Defendant’s convictions of conspiracy to commit aggravated burglary, aggravated robbery, and aggravated assault and battery. View "Jordin v. State" on Justia Law