Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court reversed the district court’s grant of summary judgment in favor of the Estate of Charles Fleig in this case challenging the rights in Charles’s checking account at Sunlight Federal Credit Union.Here, Charles and Wendy Fleig executed a signature car to add Wendy to Charles’s checking account at the Credit Union. The signature card failed to indicate whether the account would be subject to rights of survivorship. The membership and account agreement, however, provided that joint accounts had rights of survivorship unless otherwise indicated on the signature card. After Charles died, his Estate sued Wendy and the Credit Union, asserting several causes of action, including a claim for declaratory judgment regarding ownership of the checking account. The district court concluded that the signature card did not create rights of survivorship, that the account was held by Wendy and Charles as tenants in common, and that fifty percent of the account proceeds passed to the Estate and fifty percent passed to Wendy. The Supreme Court reversed, holding Wendy had a right of survivorship in the checking account because the signature card and the membership and account agreement formed the contract between the Fleigs and the Credit Union and unambiguously expressed the intent that joint accounts have rights of survivorship. View "Fleig v. Estate of Charles F. Fleig" on Justia Law

The Supreme Court affirmed Defendant’s conviction for second-degree murder, holding that, although the district court erred in some respects in instructing the jury, Defendant was not prejudiced by the errors. The Supreme Court held (1) the district court erred when it instructed the jury that Defendant had an absolute duty to retreat before using deadly force, but Defendant was not prejudiced by the instruction; (2) the district court did not violate a clear and unequivocal rule of law in instructing the jury on the mens rea element of second-degree murder; and (3) Defendant was not prejudiced when the district court failed to inform the jury that the State had the burden of proving that Defendant did not act in a sudden heat of passion in order to convict him of second-degree manslaughter. View "Sindelar v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for second-degree murder, holding that, although the district court erred in some respects in instructing the jury, Defendant was not prejudiced by the errors. The Supreme Court held (1) the district court erred when it instructed the jury that Defendant had an absolute duty to retreat before using deadly force, but Defendant was not prejudiced by the instruction; (2) the district court did not violate a clear and unequivocal rule of law in instructing the jury on the mens rea element of second-degree murder; and (3) Defendant was not prejudiced when the district court failed to inform the jury that the State had the burden of proving that Defendant did not act in a sudden heat of passion in order to convict him of second-degree manslaughter. View "Sindelar v. State" on Justia Law

The Supreme Court affirmed the order of the district court ruling that governmental immunity barred Plaintiffs’ claims against the Wyoming Department of Transportation (WYDOT), the City of Riverton (City), and their employees.Plaintiffs’ seven-year-old child was killed after being struck by a vehicle in a crosswalk on her way home from school. The driver of the vehicle held a valid Wyoming driver’s license even though she could not have passed the eye exam, which was administered by a WYDOT employee. Plaintiffs sued the WYDOT, the City, Fremont County School District No. 25, and employees of those governmental entities. The district court dismissed the claims against the school district and its employees and that governmental immunity barred the claims against the remaining defendants. The Supreme Court affirmed, holding (1) the WYDOT’s performance of eye exams does not constitute a public service for which governmental immunity has been waived under Wyo. Stat. Ann. 1-39-108; and (2) the City was not a public utility providing public services for which governmental immunity has been waived under section 1-39-108 when it provided the marked street crossing where the child was struck. View "Archer v. State ex rel. Wyoming Department of Transportation" on Justia Law

The Supreme Court affirmed the district court’s final order granting primary custody of the parties’ children to Father but reversed the court’s contempt finding against Mother.Father filed a petition seeking to modify the custody, visitation, and child support provisions of his divorce decree. After an evidentiary hearing, the district court, on its own motion, entered a temporary custody modification order, which was, in effect, a trial coparenting plan that would become permanent unless either parent requested a new hearing to establish that it was unworkable. Father filed such a motion. The district court held a second evidentiary hearing and then entered a final order granting primary custody of the children to Father. The court then held Mother in contempt of court for violating certain terms of the initial temporary order. The Supreme Court affirmed in part and reversed in part, holding (1) although the district court abused its discretion when it entered the temporary custody order, the permanent custody modification was not an abuse of discretion; and (2) the district court abused its discretion when it held Mother in contempt of court and improperly factored Mother’s contempt into her contempt motion against Father. View "Swan v. Swan" on Justia Law

The Supreme Court affirmed in part and remanded in part the final decree of divorce entered by the district court in this case.Before Wife filed for divorce from Husband, the parties executed a stipulated judgment and decree of divorce establishing property distribution, child support, child custody and visitation, and alimony. The Supreme Court held (1) the district court correctly found that the stipulated decree was a valid agreement between Husband and Wife that was supported by consideration, and the stipulated decree was not unconscionable; (2) the district court appropriate enforced the order in the divorce decree with respect to the property, debt distribution, and alimony; but (3) the district court erred in enforcing the order with respect to child custody, visitation, and child support. View "Long v. Long" on Justia Law

The Supreme Court reversed Defendant’s convictions for driving under the influence causing serious bodily injury, holding that Defendant’s conditional no contest plea to the charge was not proper. Because Defendant did not present a proper cognitional plea, reversal of the district court’s order was required because “the issues are clearly controlled by settled Wyoming law.” Therefore, the Court entered an abbreviated opinion pursuant to Wyo. R. App. P. 9.06 and remanded the case to the district court for proceedings consistent with this opinion. View "Hardman v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of Defendants on Plaintiff’s lawsuit seeking to prevent the sale of land held in Allen F. Willey’s revocable trust. The district court determined that Plaintiffs - the grandchildren of Mr. Willey - were no longer beneficiaries of the trust as a result of their father’s 2014 lawsuit against Mr. Willey and his wife. The Supreme Court held (1) the 2014 suit constituted a “challenge” to the trust even though the suit was filed during Mr. Willey’s lifetime; and (2) the in terrorem clause in Mr. Willey’s trust did not violate public policy. View "EGW v. First Federal Savings Bank of Sheridan, Wyoming" on Justia Law

The Supreme Court remanded this case for a new hearing under Batson v. Kentucky, 476 U.S. 79 (1986), holding that the district court clearly erred by allowing the State to exercise a peremptory challenge to exclude an African American from the jury. The record supported the validity of only one of the prosecutor’s race-neutral reasons for his peremptory challenge and did not show that the district court would credit this reason alone. Specifically, one of the prosecutor’s two explanations for the peremptory challenge upon which the district court relied failed, and the record did not show that the district court would find that the prosecutor was motivated solely by the valid grounds. Therefore, the case must be remanded for a new Batson hearing in which the district court must reassess the prosecutor’s credibility in light of the discrepancy between the record and his explanation. View "Roberts v. State" on Justia Law

The Supreme Court remanded this case for a new hearing under Batson v. Kentucky, 476 U.S. 79 (1986), holding that the district court clearly erred by allowing the State to exercise a peremptory challenge to exclude an African American from the jury. The record supported the validity of only one of the prosecutor’s race-neutral reasons for his peremptory challenge and did not show that the district court would credit this reason alone. Specifically, one of the prosecutor’s two explanations for the peremptory challenge upon which the district court relied failed, and the record did not show that the district court would find that the prosecutor was motivated solely by the valid grounds. Therefore, the case must be remanded for a new Batson hearing in which the district court must reassess the prosecutor’s credibility in light of the discrepancy between the record and his explanation. View "Roberts v. State" on Justia Law