Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed Appellant’s conviction for delivery of a controlled substance, methamphetamine, holding that, even if the photographic identification procedure used by law enforcement during their investigation of the crime was impermissibly suggestive, it did not give rise to a very substantial likelihood of irreparable misidentification.During the proceedings below, Appellant challenged the photo identification in a motion in limine. The motion was denied. On appeal, Appellant argued that the photo identification procedure violated his due process rights. The Supreme Court disagreed, holding that the identification was sufficiently reliable to satisfy the demands of due process, and therefore, the district court did not err in admitting the identification. View "Majhanovich v. State" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence that led to Defendant’s conviction for marijuana possession.Corporal Bradley Halter stopped Defendant for a traffic violation. When Defendant attempted to walk away from the traffic stop, Corporal Halter handcuffed Defendant. Because Defendant smelled of marijuana and was impaired, Corporal conducted a search of Defendant’s person, which produced methamphetamine, and, after a subsequent search, marijuana and hashish. After the denial of his motion to suppress, Defendant entered a conditional plea to the possession of marijuana. The Supreme Court affirmed, holding that Corporal Halter’s seizure of the methpahetamine and subsequent search was supported by both the plain feel doctrine and by standard probable cause considerations. View "Maestas v. State" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence that led to Defendant’s conviction for marijuana possession.Corporal Bradley Halter stopped Defendant for a traffic violation. When Defendant attempted to walk away from the traffic stop, Corporal Halter handcuffed Defendant. Because Defendant smelled of marijuana and was impaired, Corporal conducted a search of Defendant’s person, which produced methamphetamine, and, after a subsequent search, marijuana and hashish. After the denial of his motion to suppress, Defendant entered a conditional plea to the possession of marijuana. The Supreme Court affirmed, holding that Corporal Halter’s seizure of the methpahetamine and subsequent search was supported by both the plain feel doctrine and by standard probable cause considerations. View "Maestas v. State" on Justia Law

The Supreme Court affirmed the district court’s order denying Appellant’s motion to suppress the marijuana Trooper Aaron Kirlin discovered in Appellant’s possession during a traffic stop on Interstate 80.Appellant pleaded guilty to possession of marijuana, preserving his right to appeal the district court’s denial of his motion to suppress. On appeal, Appellant argued that Trooper Kirlin unlawfully detained him beyond the original purpose of the traffic stop in violation of his Fourth Amendment rights. The Supreme Court disagreed, holding that the district court did not err in determining that Trooper Kirlin’s extended contact with Appellant was a consensual encounter that did not violate the Fourth Amendment. View "Kennison v. State" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the decision of the district court granting summary judgment to Anethesiology Consultants of Cheyenne, LLC (ACC) on its breach of fiduciary duty claim and on Dr. Ronald Stevens’ defamation counterclaim.ACC filed suit against Dr. Stevens and Cassandra Rivers alleging nine causes of action. Dr. Stevens counterclaimed against the members of ACC, alleging several causes of action, including defamation. The district court granted summary judgment for ACC on its first three causes of action and granted summary judgment for the counterclaims defendants on all of Dr. Stevens’ counterclaims. On appeal, the Supreme Court held (1) summary judgment was improperly granted on the fiduciary duties claims; (2) summary judgment was properly granted on the defamation counterclaim; and (3) the trial court erred in excluding certain email evidence. View "Stevens v. Anesthesiology Consultants of Cheyenne, LLC" on Justia Law

The Supreme Court affirmed the district court’s dismissal of Appellants’ complaint against a school district and school district employees (collectively, Appellees), holding that Appellees were immune from suit under the Wyoming Governmental Claims Act, Wyo. Stat. Ann. 1-39-101 through 1-39-121.Appellants filed this action alleging that the school district employees had committed various torts against them, that the school district was liable for the employees’ actions under the doctrine of respondeat superior, and that the school district had committed direct acts of negligence. The district court dismissed the case under Wyo. R. Civ. P. 12(b)(6). The Supreme Court affirmed, holding (1) Appellants did not properly allege that the school district employees acted outside the scope of their duties, and therefore, the district court did not err by dismissing Appellants’ claims against the employees; (2) this Court rejects Appellants’ request to recognize an exception to immunity for violation of school policy and/or criminal conduct; and (3) Appellants’ remaining argument was without merit. View "Whitham v. Feller" on Justia Law

The Supreme Court affirmed the decision of the district court denying Defendant’s motions to continue Defendant’s trial but remanded to the district court with instructions to correct the written sentence, holding that while Defendant’s sentence was not illegal, the written sentence was inconsistent with the district court’s oral sentence.After a trial, Defendant was convicted of one felony count of interference with a peace officer and one misdemeanor count of interference with a peace officer for resisting arrest. The court orally sentenced Defendant to seven to nine years on the felony count and to one year on the misdemeanor count. The court allowed credit for 408 days already served and specified that the credit applied to both sentences. The court did not specify whether the sentences were to be served concurrently or consecutively. The Supreme Court held (1) the district court did not abuse its discretion when it denied Defendant’s last two motions to continue his trial; and (2) because the written sentence did not indicate whether the two sentences were to be served concurrently or consecutively and allowed 408 days credit but did not specify that the credit applied to both sentences, remand was necessary to correct the written sentence. View "Palomo v. State" on Justia Law

The Supreme Court affirmed the district court order denying the motion of Speedy Bail Bonds seeking to set aside the forfeiture of a $50,000 surety bond it posted on behalf of a defendant in a drug trafficking case, holding that the district court did not abuse its discretion. In affirming, the Supreme Court looked to whether the district court improperly relied on punitive motives for the forfeiture and examined the district court’s consideration of relevant matters such as any factors presented by the defendant which might mitigate his failure to appear at his arraignment. After examining the evidence, the Court held that the district court’s decision was reasonable based on the evidence. View "Speedy Bail Bonds v. Albany County, Wyoming" on Justia Law

The Supreme Court affirmed the district court order denying the motion of Speedy Bail Bonds seeking to set aside the forfeiture of a $50,000 surety bond it posted on behalf of a defendant in a drug trafficking case, holding that the district court did not abuse its discretion. In affirming, the Supreme Court looked to whether the district court improperly relied on punitive motives for the forfeiture and examined the district court’s consideration of relevant matters such as any factors presented by the defendant which might mitigate his failure to appear at his arraignment. After examining the evidence, the Court held that the district court’s decision was reasonable based on the evidence. View "Speedy Bail Bonds v. Albany County, Wyoming" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the order of the district court granting Father’s petition to modify the parties’ divorce decree. The Court held that the district court (1) did not err in concluding that Father had established a material change in circumstances to reopen the visitation provision of the decree and then modifying the decree to extend Father’s summer visitation; (2) did not have the authority to modify the original decree’s provisions regarding medical payments; and (3) abused its discretion by allowing Father to claim the children as dependents for tax purposes every other year. View "Meehan-Greer v. Greer" on Justia Law