Justia Wyoming Supreme Court Opinion Summaries

Jennifer Lynch pled guilty to one count of misdemeanor endangering children and one count of felony child abuse. She appealed her child abuse conviction, arguing that there was no factual basis to support the charge and that the district court abused its discretion in denying her post-sentence motion to withdraw her guilty plea.The District Court of Carbon County initially accepted Lynch's guilty plea after a colloquy to ensure it was made voluntarily. Lynch admitted to giving her prescription Seroquel to her mother, who then administered it to her children. The court found this sufficient to support the plea. Lynch was sentenced to nine-to-ten years in prison for child abuse and 25 days in jail for endangering children. She later filed a motion to withdraw her guilty plea, which the district court denied.The Supreme Court of Wyoming reviewed the case and found that the district court erred in accepting Lynch's guilty plea without a sufficient factual basis. The court noted that while Lynch admitted to giving Seroquel to her children, there was no evidence that this caused the physical injury required for a child abuse conviction under Wyoming law. The court emphasized that the factual basis must establish all elements of the charged crime, including physical injury, which was not demonstrated in this case.The Supreme Court of Wyoming reversed Lynch's child abuse conviction and remanded the case for further proceedings, finding that the district court's acceptance of the guilty plea without a sufficient factual basis materially prejudiced Lynch's substantial rights. View "Lynch v. The State of Wyoming" on Justia Law

In early fall 2021, JM, a student at Cody High School, disclosed to her counselor that her biological father, Dustin M. Sanchez, had inappropriately touched her during a visit in June 2021. JM reported that while watching a movie, Sanchez put his arm around her, reached across her chest, and placed his hand on her left breast under her shirt and bra. Despite her attempts to move away, Sanchez kept her close until she excused herself to go to the bathroom and texted her grandmother to pick her up. Sanchez was subsequently charged with one count of second-degree sexual abuse of a minor.The District Court of Park County conducted a three-day jury trial, resulting in Sanchez's conviction. He was sentenced to eight-to-ten years in prison. Sanchez appealed, arguing that the evidence was insufficient to sustain his conviction and that the prosecutor committed misconduct by misstating the law during closing and rebuttal arguments.The Wyoming Supreme Court reviewed the case. The court held that the evidence was sufficient to support Sanchez's conviction. The court noted that Sanchez, as JM's biological father, occupied a "position of authority" under Wyoming Statute § 6-2-315(a)(iv), which does not require additional proof of significant influence over the victim if the defendant falls into one of the statute’s enumerated categories, such as a parent. The court also found that the prosecutor did not misstate the law during closing arguments. The prosecutor's statements were consistent with the legal interpretation that Sanchez, as JM’s parent, inherently occupied a position of authority. Consequently, the court affirmed Sanchez's conviction and sentence. View "Sanchez v. The State of Wyoming" on Justia Law

Ming Zheng, a drilling field engineer, suffered a work-related injury to her right ankle while attempting to disassemble a tool string. She reported the injury and received workers' compensation benefits. Approximately a year later, Zheng sought additional benefits for an injury to her left ankle and requested preauthorization for surgery on her right ankle. The Wyoming Department of Workforce Services, Workers' Compensation Division, denied these requests, finding the treatments were not related to her original work injury. The Division also discontinued her temporary total disability benefits after she received a 0% impairment rating.The Wyoming Medical Commission upheld the Division's denial of benefits and discontinuation of temporary total disability benefits after a contested case hearing. The Commission found that Zheng failed to prove the requested treatments for her left ankle were related to her compensable work injury and that the surgery on her right ankle was necessary. The district court affirmed the Medical Commission's decision.The Wyoming Supreme Court reviewed the case and affirmed the lower court's decision. The Court held that substantial evidence supported the Medical Commission's findings that Zheng's left ankle issues were not related to her work injury and that the requested surgery on her right ankle was not necessary. The Court also found that the Medical Commission did not act arbitrarily or capriciously in admitting an addendum to Dr. Orth's independent medical evaluation, as Zheng had the opportunity to cross-examine Dr. Orth and present rebuttal evidence. The Court concluded that the Medical Commission's decision was supported by substantial evidence and was not arbitrary or capricious. View "Zheng v. State of Wyoming, Ex Rel. Department of Workforce Services" on Justia Law

Rick James Little was found guilty by a jury of one count of sexual abuse of a minor in the third degree and one misdemeanor count of attempted sexual battery. He filed a motion for a new trial, claiming ineffective assistance of counsel. The district court denied the motion, concluding that Mr. Little failed to show a reasonable probability that the outcome of the trial would have been more favorable absent any deficiencies in his counsel’s performance.The District Court of Campbell County initially reviewed the case. Mr. Little's defense argued that he was not present at the scene of the alleged crimes. However, during the trial, the prosecution presented strong evidence, including testimony from the victims and their mother, as well as a text message from Mr. Little that placed him at the scene. Mr. Little's counsel introduced his prior convictions during voir dire and opening statements, which Mr. Little later claimed was a strategic error. The district court found that the defense strategy, although unorthodox, was not unreasonable given Mr. Little's insistence on testifying.The Wyoming Supreme Court reviewed the case. The court held that Mr. Little did not demonstrate a reasonable probability that the trial outcome would have been different without the alleged deficiencies in his counsel’s performance. The court noted that the evidence against Mr. Little was strong, including detailed testimonies from the victims and corroborating evidence from their mother. The court also found that the potential alibi witness, Amber Everly, was equivocal about Mr. Little’s presence at her house on the night of the incident, and the text message evidence was dispositive. Consequently, the Wyoming Supreme Court affirmed the district court’s decision, concluding that Mr. Little was not denied effective assistance of counsel. View "Little v. The State of Wyoming" on Justia Law

A mother challenged the juvenile court's finding that she neglected her four-year-old child, RTB. The case began when the mother tested positive for methamphetamine, amphetamines, and marijuana during a medical appointment. Concerned for RTB's welfare, the healthcare provider reported the results to the Department of Family Services. A caseworker and a police officer visited the mother's home, where she again tested positive for the same substances. The officer took RTB into protective custody due to the mother's drug use and the lack of an appropriate caregiver in the home.The State filed a petition alleging neglect, and the juvenile court held a shelter care hearing, granting the Department legal custody of RTB. At a subsequent hearing, the court ordered RTB to be returned to the mother but retained legal custody with the Department pending an adjudicatory hearing. During the adjudicatory hearing, the State presented testimony from a Department supervisor, the police officer, and the mother, among others. The court found the mother neglected RTB and entered a written order to that effect.The Wyoming Supreme Court reviewed the case and affirmed the juvenile court's decision. The court held that the officer had reasonable grounds to take RTB into protective custody based on the mother's positive drug tests and the lack of a suitable caregiver. The court also found sufficient evidence to support the juvenile court's decision to place RTB in shelter care and to adjudicate the mother as neglectful. The evidence included the mother's repeated positive drug tests, her erratic behavior, and the unsafe environment in the home. The court concluded that the mother's actions constituted neglect as defined by Wyoming law. View "In the Interest of Minor Child v. The State of Wyoming" on Justia Law

Chadwick R. Traylor challenged the testamentary trust of his father, Donald R. Traylor, alleging undue influence by the defendants, who were beneficiaries under the trust. Traylor claimed that the defendants manipulated his father into amending the trust to their benefit. The district court, after a bench trial, denied Traylor’s claims and enforced the trust’s no-contest clause against him.The District Court of Natrona County initially set the case for a jury trial but later struck Traylor’s jury demand as untimely. Traylor argued that the demand was timely because not all defendants had answered, but the court disagreed, ruling that the time for serving the demand began when Traylor answered the defendants’ counterclaims. The court also denied Traylor’s subsequent motion for reconsideration and his request for a jury trial under W.R.C.P. 39(b), finding no extraordinary circumstances to justify such relief.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The Supreme Court held that Traylor waived his right to a jury trial by failing to timely serve his demand. The court also found no abuse of discretion in the district court’s denial of Traylor’s Rule 39(b) request for a jury trial. Additionally, the Supreme Court ruled that the district court applied the correct burden of proof, requiring Traylor to prove undue influence by a preponderance of the evidence, not by clear and convincing evidence. The court found that Traylor failed to meet this burden.The Supreme Court also upheld the district court’s enforcement of the no-contest clause against Traylor, interpreting the trust’s language to include him as a beneficiary subject to the clause. Finally, the Supreme Court found no abuse of discretion in the district court’s award of costs to the defendants, noting that Traylor did not provide an adequate record for review. The court affirmed the district court’s judgment in all respects. View "Traylor v. Green" on Justia Law

Donald and Mary Fuger own forty acres of land in Wyoming. Larry Wagoner began using a five-acre section of this land for his oilfield business around 2008. The Fugers and Wagoner agreed to construct two buildings on the site, with Wagoner handling construction and the Fugers securing financing. They did not formalize this agreement in writing. A lease agreement was signed, giving Wagoner exclusive use of the buildings for five years. Wagoner claimed there was an oral agreement to transfer ownership of one building and the land to him in exchange for his construction work and loan payments, which the Fugers denied.The District Court of Sweetwater County initially found in favor of Wagoner, awarding him damages for breach of the oral contract. However, the Wyoming Supreme Court reversed this decision in Fuger v. Wagoner, 2020 WY 154, ruling the oral contract void because Mrs. Fuger did not join the agreement. The case was remanded to consider Wagoner’s equitable claims. On remand, the district court found the Fugers were unjustly enriched by Wagoner’s construction work and awarded him damages, offsetting some of these due to his use of the buildings. The court also awarded prejudgment interest on a portion of the damages.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court held that the district court did not err in offsetting Wagoner’s damages by the actual rent he received rather than the fair rental value of the second building. The court also upheld the award of prejudgment interest, finding that a portion of Wagoner’s damages were liquidated and thus subject to such interest. The court concluded that the district court acted within its discretion in its equitable determinations regarding offset and prejudgment interest. View "Fuger v. Wagoner" on Justia Law

The case involves Andrew James Keller, who pleaded guilty to one count of conspiracy to deliver methamphetamine. Keller, representing himself, argued that the district court erred by denying his motion to withdraw his guilty plea under Wyoming Rule of Criminal Procedure (W.R.Cr.P.) 32(d) and his subsequent Wyoming Rule of Appellate Procedure (W.R.A.P.) 21 motion to withdraw his guilty plea and for a new trial due to ineffective assistance of counsel. He claimed that his public defenders had conflicts of interest and did not provide reasonably competent assistance.The district court denied Keller's motion to withdraw his guilty plea, concluding that he did not establish a fair and just reason to withdraw his guilty plea under Rule 32(d). Keller then filed a motion to withdraw his guilty plea and for a new trial under W.R.A.P. 21, claiming he received ineffective assistance from his three defense attorneys. The district court denied Keller's Rule 21 motion and issued findings of fact and conclusions of law in support of its decision.The Supreme Court of Wyoming affirmed the district court's decision. The court found that Keller failed to establish that his attorneys' performance was deficient, and thus, he did not receive ineffective assistance of counsel. The court also found that Keller failed to present a fair and just reason to withdraw his guilty plea under W.R.Cr.P. 32(d). View "Keller v. The State of Wyoming" on Justia Law

Mitchell Rataiczak and Gwendolyn Parker, who were never married, are the biological parents of two minor children. After their relationship ended, Parker moved to Wyoming with the children, while Rataiczak remained in Arizona. Rataiczak filed a petition to establish paternity, custody, visitation, and child support. The District Court of Park County awarded joint legal custody to both parents, primary physical custody to Parker, and visitation rights to Rataiczak. The court also ordered Rataiczak to pay child support.The district court's visitation schedule was graduated, requiring Rataiczak to visit the children in Wyoming for a certain number of days each year, with no overnights initially allowed. The court also ordered Rataiczak to be solely responsible for transportation costs, but made no adjustment to his child support obligation.Rataiczak appealed to the Supreme Court of Wyoming, arguing that the district court abused its discretion in setting the visitation schedule and in not adjusting his child support obligation in light of the transportation costs. The Supreme Court found that the visitation provisions were not clear enough to promote understanding and compliance, and that the graduated visitation schedule was unreasonable and unsupported by the evidence. The court also found that the district court should have considered whether an adjustment to Rataiczak's child support obligation or the allocation of transportation costs was appropriate in light of the visitation determination. The Supreme Court reversed the district court's decision and remanded the case for further proceedings. View "Rataiczak v. Parker" on Justia Law

This case involves a dispute over a parcel of land between two neighboring property owners in Park County, Wyoming. The appellants, Michael and Michelle Sellers, purchased a 12-acre property that was adjacent to a 4-acre parcel owned by the appellees, Phyllis Claudson, William Pond, Pamela Pond, and Peggy Lou Pond Paul. During the purchase, the Sellers discovered that a portion of their property was located on the Ponds' side of a boundary fence. The Ponds filed a lawsuit to claim ownership of this portion of land based on adverse possession.The District Court of Park County initially heard the case. The Ponds and the Sellers filed cross-motions for summary judgment. The district court ruled in favor of the Ponds, finding that they had adversely possessed the disputed property. The Sellers appealed this decision.The Supreme Court of Wyoming reviewed the case and affirmed the lower court's decision. The court found that the Ponds had established a prima facie case for adverse possession. They had shown actual, open, notorious, exclusive, and continuous possession of the disputed property, which was hostile and under claim of right or color of title. The Sellers failed to rebut this claim by showing permissive use of the property through neighborly accommodation. The court also rejected the Sellers' argument that the Ponds could only have adversely possessed the areas of the property containing buildings, as the Sellers had not raised this issue in the lower court. View "Sellers v. Claudson" on Justia Law