Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court reversed the district court’s denial of Defendant’s motion to modify his original sentence after a new individualized sentencing hearing and remanded for a new individualized sentencing hearing.Defendant was seventeen years old when he and his friend robbed and murdered a hitchhiker. Defendant was sentenced to life imprisonment with a consecutive twenty-to-fifty-year sentence for aggravated robbery. Following the decisions in Miller v. Alabama, 567 U.S. 460 (2012), Montgomery v. Louisiana, __ U.S. __ (2016), and Bear Cloud v. State, 294 P.3d 36 (Wyo. 2013), and the Wyoming Legislature’s amendment to Wyo. Stat. Ann. 6-10-301(c), Defendant was granted parole from his life sentence and began serving his consecutive twenty-to-fifty-year sentence. Defendant received a new individualized sentencing hearing, after which the district court declined to modify Defendant’s original sentence. The Supreme Court reversed and remanded for an additional sentencing hearing because at the time of the hearing and the district court’s decision, the parties and the district court did not have the advantage of this Court’s rulings concerning the procedure, burdens, and potentially relevant evidence for a Miller determination contained within this opinion. View "Davis v. State" on Justia Law

The Supreme Court affirmed the district court’s grant of summary judgment in favor of Bank in this quiet title action.Plaintiff filed suit seeking to quiet title to property he purchased at a tax sale. Bank, the mortgagee on the property and a defendant in the quiet title suit, alleged that Plaintiff’s tax deed was void. The district court granted summary judgment for Bank, concluding that the statutorily-required notice regarding redemption provided by Plaintiff to the property owner and to Bank was deficient and that the tax deed was void. The Supreme Court affirmed, holding (1) Bank had standing to challenge the validity of Plaintiff’s tax deed; (2) because Plaintiff failed to notify Bank of the redemption period, the tax deed was void; (3) the district court’s reference to a document not contained in the record was error, but it was not reversible error because that document was not relevant to the material facts in this case; (4) the doctrine of laches and unclean hands did not bar Bank’s arguments regarding the validity of the tax deed; and (5) Plaintiff’s statutory claims for reimbursement were not ripe for review. View "Montierth v. Deutsche Bank National Trust Co." on Justia Law

The Supreme Court affirmed the district court’s denial of Mother’s motion to set aside the clerk of court’s entry of default against her after she did not respond to the petition of the Department of Family Services to terminate her parental rights within twenty days after service.In denying Mother’s motion, the district court found that Mother did not present good cause to set aside the entry of default. After a default evidentiary hearing, the district court terminated Mother’s parental rights. The Supreme Court affirmed, holding the district court did not abuse its discretion when it applied the three-factor test applied in civil actions to determine a motion to set aside the entry of default judgment and weighed the three factors to deny Mother’s motion to set aside the entry of default against her. View "Hurd v. State, Department of Family Services" on Justia Law

Wyo. Stat. Ann. 27-14-605 does not bar a claimant from receiving temporary total disability benefits for a second compensable injury when he has not filed a claim for benefits on his original injury within four years.Six years after receiving workers’ compensation benefits for a workplace injury to his right knee, James Hall underwent another knee surgery that was approved by the Workers’ Compensation Division. The Division denied Hall’s application for temporary total disability (TTD) benefits, concluding that, under section 27-14-605(b), Hall was not entitled to TTD benefits related to the surgery after not seeking benefits on his original injury for over four years. The Office of Administrative Hearings (OAH), however, concluded that section 27-14-605 did not govern Hall’s claim because Hall suffered a second compensable injury that section 27-14-605 did not control and that Hall was entitled to TTD benefits as a matter of law. The district court affirmed. The Supreme Court affirmed, holding that Hall suffered a second compensable injury and was therefore entitled to TTD benefits pursuant to Wyo. Stat. Ann. 27-14-404(a). View "In re Worker's Compensation Claim of James A. Hall" on Justia Law

The Supreme Court affirmed the district court’s grant of summary judgment in favor of Plaintiff in this declaratory judgment action against the Board of County Commissioners of Teton County challenging the Teton County Land Development Regulation prohibiting fractional ownership of campgrounds, holding that the regulation was unenforceable because it exceeded the County’s zoning authority. Specifically, the Court agreed with Plaintiff that the regulation prohibiting fractional ownership did not regulate the use of the land, only its ownership, and was, therefore, beyond the County’s zoning authority and unenforceable. View "Board of County Commissioners of Teton County, Wyoming v. Mackay Investments, LLC" on Justia Law

The Supreme Court affirmed the decision of the district court affirming the decision in favor of Petitioner’s former attorneys (Respondent-law firm) by a panel of the Wyoming State Bar Committee for Resolution of Fee Disputes. The Court held (1) the panel’s conclusion that it was neither unreasonable nor abusive for Respondent to bill its time using minimum increments of fifteen minutes was supported by substantial evidence; and (2) substantial evidence supported the panel’s conclusion that Respondent exercised billing judgment and did not excessively bill Petitioner for substantive and necessary communication between firm members and employees about Petitioner's case. View "Manigault v. Daly & Sorenson, LLC" on Justia Law

The Supreme Court affirmed the decision of the district court affirming the decision in favor of Petitioner’s former attorneys (Respondent-law firm) by a panel of the Wyoming State Bar Committee for Resolution of Fee Disputes. The Court held (1) the panel’s conclusion that it was neither unreasonable nor abusive for Respondent to bill its time using minimum increments of fifteen minutes was supported by substantial evidence; and (2) substantial evidence supported the panel’s conclusion that Respondent exercised billing judgment and did not excessively bill Petitioner for substantive and necessary communication between firm members and employees about Petitioner's case. View "Manigault v. Daly & Sorenson, LLC" on Justia Law

The Supreme Court reversed the order of the district court granting summary judgment in favor of the State in this action filed by Mark Gordon in his capacity as the State Treasurer challenging on its face the constitutionality of legislation that created the State Capitol Building Rehabilitation and Restoration Oversight Group (oversight group). In his complaint, Gordon argued that the legislation violated article 3, section 31 and article 2, section 1 of the Wyoming Constitution because, in part, it did not provide for the state treasurer’s approval of contracts for the capitol restoration project. The district court concluded that Gordon failed to establish that the capitol restoration legislation violated the constitution on its face or that the work being done on the project was the type of repair work contemplated by the framers when they adopted article 3, section 31. The Supreme Court reversed, holding that the capitol restoration legislation was unconstitutional on its face because it impermissibly transferred the state treasurer’s constitutional authority to approve contracts for “repairing and furnishing the halls and rooms used for the meeting of the legislature and its committees” to others. View "Gordon v. State" on Justia Law

The Supreme Court reversed the order of the district court granting summary judgment in favor of the State in this action filed by Mark Gordon in his capacity as the State Treasurer challenging on its face the constitutionality of legislation that created the State Capitol Building Rehabilitation and Restoration Oversight Group (oversight group). In his complaint, Gordon argued that the legislation violated article 3, section 31 and article 2, section 1 of the Wyoming Constitution because, in part, it did not provide for the state treasurer’s approval of contracts for the capitol restoration project. The district court concluded that Gordon failed to establish that the capitol restoration legislation violated the constitution on its face or that the work being done on the project was the type of repair work contemplated by the framers when they adopted article 3, section 31. The Supreme Court reversed, holding that the capitol restoration legislation was unconstitutional on its face because it impermissibly transferred the state treasurer’s constitutional authority to approve contracts for “repairing and furnishing the halls and rooms used for the meeting of the legislature and its committees” to others. View "Gordon v. State" on Justia Law

The Supreme Court affirmed the district court’s entry of an order nunc pro tunc correcting two judgments entered against Defendant in 1998. The Court held (1) the district court had jurisdiction to enter the order nunc pro tunc irrespective of whether the Department of Corrections had standing to challenge the erroneous judgments; (2) there was no merit in Appellant’s claim that the Department of Corrections was required to seek reimbursement pursuant to Wyo. Stat. Ann. 7-6-108; and (3) as to Defendant’s remaining issues on appeal, he provided no cogent argument or pertinent authority to support either of his claims, and therefore, this Court will not consider them. View "Heinemann v. State" on Justia Law