Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the district court ruling that the Office of Administrative Hearings (OAH) erred in upholding the Wyoming Workers’ Compensation Division’s denial of benefits to Richard Williams.Williams suffered a head injury while working as a well operator. Williams argued that a flash fire started him and caused him to fall backward and strike his head. The Division denied benefits, determining that Williams’ injury did not arise out of an in the course of his employment. The OAH upheld the denial of benefits, finding that Williams and his version of events lacked credibility. The district court reversed, concluding that the OAH decision was contrary to overwhelming medical evidence that Williams injured his head while engaged in work-related activities. The Supreme Court affirmed, holding that Williams offered evidence sufficient to raise a presumption that he suffered a head injury that arose out of his employment and that the Division failed to rebut that presumption. View "State ex rel. Department of Workforce Services, Workers' Compensation Division v. Williams" on Justia Law

The Supreme Court affirmed the order of the trial court convicting Defendant on a charge of first-degree arson. On appeal, Defendant argued that the district court abused its discretion when, at trial, it admitted evidence of other acts, in violation of Wyo. R. Evid. 404(b). The Supreme Court disagreed, holding (1) the district court did not commit plain error when it conducted its Rule 404(b) Gleason analysis after the disputed Rule 404(b) evidence had been admitted and after the close of the evidence; and (2) the district court did not abuse its discretion when it admitted evidence of other acts at trial. View "Garrison v. State" on Justia Law

The Supreme Court affirmed the decision of the district court finding that Plaintiffs, two Wyoming citizens, lacked standing to challenge legislation that authorized two construction projects while maintaining a degree of legislative control and that Plaintiffs’ proposed amendment to their complaint would be futile.In their complaint, Plaintiffs alleged that the legislation at issue violated the Wyoming Constitution and that government officials unconstitutionally engaged in a pattern of letting state contracts without competitive bidding or required safeguards. The district court found that Plaintiffs lacked standing and that their proposed amendment to add a third plaintiff who would have alleged economic harm resulting from the contracting practices would be futile. The Supreme Court affirmed, holding (1) Plaintiff lacked standing to bring this lawsuit; and (2) because there was no justiciable controversy, this court declines to address the constitutionality of a statute enacted in 2017 that prohibits naming a legislator in a lawsuit if he or she is sued in an official capacity. View "Allred v. Bebout" on Justia Law

The Supreme Court affirmed the decision of the district court finding that Plaintiffs, two Wyoming citizens, lacked standing to challenge legislation that authorized two construction projects while maintaining a degree of legislative control and that Plaintiffs’ proposed amendment to their complaint would be futile.In their complaint, Plaintiffs alleged that the legislation at issue violated the Wyoming Constitution and that government officials unconstitutionally engaged in a pattern of letting state contracts without competitive bidding or required safeguards. The district court found that Plaintiffs lacked standing and that their proposed amendment to add a third plaintiff who would have alleged economic harm resulting from the contracting practices would be futile. The Supreme Court affirmed, holding (1) Plaintiff lacked standing to bring this lawsuit; and (2) because there was no justiciable controversy, this court declines to address the constitutionality of a statute enacted in 2017 that prohibits naming a legislator in a lawsuit if he or she is sued in an official capacity. View "Allred v. Bebout" on Justia Law

The Supreme Court reversed the district court’s ruling granting summary judgment against FedEx Ground Package System, Inc. on Mariusz Bogdanski’s claim of vicarious liability of the claimed negligence of Damian Budzik and remanded the case to the district court for further proceedings.Bogdanski and Budzik were codrivers of a semi-truck that was involved in an accident in Evanston, Wyoming. The codrivers were hauling trailers owned by FedEx. Bogdanski sued Budzik, seeking damages for Budzik’s claimed negligence. Bogdanski also sued FedEx. The district court granted summary judgment in favor of Budzik and FedEx. The Supreme Court (1) affirmed the summary judgment in favor of Budzik and the summary judgment on Bogdanski’s direct negligent training claim; but (2) reversed the summary judgment against FedEx on the vicarious liability for claimed negligence claim, holding that the evidence was sufficient to raise a genuine issue as to whether Budzik breached a duty. View "Bogdanski v. Budzik" on Justia Law

The Supreme Court affirmed the order of the district court sentencing Defendant to a prison term of four to six years, suspended in favor of six years of supervised probation, and ordering Defendant to pay restitution to her victim as a condition of her probation.Defendant pled guilty to exploitation of a vulnerable adult. In sentencing Defendant, the district court placed a number of conditions on her probations, including that Defendant pay restitution to the victim. On appeal, Defendant argued that the district court was without authority to setting her restitution payments at $500 per month, restricting Defendant from purchasing cable television or cell phone services, and directing that her recreational vehicles and trailers be liquidated. The Supreme Court affirmed, holding that the district court did not abuse its discretion or exceed its authority in imposing the conditions at issue in this case. View "Anderson v. State" on Justia Law

The Supreme Court affirmed the order of the district court sentencing Defendant to a prison term of four to six years, suspended in favor of six years of supervised probation, and ordering Defendant to pay restitution to her victim as a condition of her probation.Defendant pled guilty to exploitation of a vulnerable adult. In sentencing Defendant, the district court placed a number of conditions on her probations, including that Defendant pay restitution to the victim. On appeal, Defendant argued that the district court was without authority to setting her restitution payments at $500 per month, restricting Defendant from purchasing cable television or cell phone services, and directing that her recreational vehicles and trailers be liquidated. The Supreme Court affirmed, holding that the district court did not abuse its discretion or exceed its authority in imposing the conditions at issue in this case. View "Anderson v. State" on Justia Law

The Supreme Court affirmed the district court’s order, entered after a jury trial, terminating Father’s parental rights to his infant daughter. The court held (1) the evidence in this case was clear and convincing and allowed the jury reasonably to find that Appellant was not a fit parent under the provisions of Wyo. Stat. Ann. 14-2-309(a)(iv); and (2) the Department of Family Services failed to comply its rule establishing deadlines for completing a case plan, but the error was harmless, and therefore, the district court did not err when it denied Father’s motion for judgment as a matter of law. View "Anastos v. State, Department of Family Services" on Justia Law

The Supreme Court affirmed Defendant’s conviction for one count of conspiracy to deliver a controlled substance, methamphetamine, thus rejecting Defendant’s claims of error on appeal. Specifically, the court held (1) the trial court did not abuse its discretion or commit plain error in admitting certain testimony into evidence; (2) the trial court did not err in denying Defendant’s motion to dismiss on Fifth Amendment double jeopardy grounds; and (3) plain error did not occur when a law enforcement witness offered his opinion that Defendant committed the crime of conspiracy to deliver methamphetamine. View "Garriott v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of three counts of aggravated assault and battery and one count of domestic battery and sentencing Defendant to enhanced penalties under the habitual criminal statute. The court held (1) there was sufficient evidence to support Defendant’s assault and battery convictions; (2) the district court did not commit reversible error when it allowed the jury to hear testimony of domestic violence expert and evidence that the victim had been abused in prior relationships; and (3) the district court did not impose illegal sentences. View "Thompson v. State" on Justia Law