Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court convicting Defendant of strangulation of a household member, in violation of Wyo. Stat. Ann. 6-2-509(a)(i). The court held (1) contrary to Defendant’s argument on appeal, the prosecutor did not commit misconduct by withholding exculpatory information from the defense in violation of Brady v. Maryland, 373 U.S. 83 (1963); and (2) the evidence presented at trial was sufficient to sustain Defendant’s conviction of strangulation of a household member because there was sufficient evidence to support the conclusion that pressure was applied to the victim’s throat or neck and that any bodily injury was caused by impeding breathing or circulation. View "Davis v. State" on Justia Law

The Supreme Court affirmed the order of the district court modifying child support with respect to Mother’s daughter. In 2011, Mother and Father entered into an agreement modifying Father’s child support obligation. Approximately five years later, at Mother’s request, the Child Support Enforcement Program filed a petition to modify Father’s child support obligation. The district court entered an order modifying child support but granted a downward deviation from the presumptive child support. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by using the matrix for two children rather than one child when it calculated a deviation from the presumptive child support; and (2) properly made specific findings in its order for the reasons it granted a deviation pursuant to Wyo. Stat. 20-2-307(b). View "TSR v. State, ex rel., Department of Family Services" on Justia Law

The Supreme Court affirmed the order of the district court striking RB’s appearance in the underlying adoption action and granting the foster parents’ petition for adoption of SSO, the biological son of RB. The adoption court determined that RB’s parental rights had previously been terminated, and therefore, RB had no standing to enter an appearance in the adoption case or to challenge the adoption. RB appealed the order granting the foster parents’ motion to strike his entry of appearance and objection to SSO’s adoption, and of the adoption order. The Supreme Court held (1) the district court properly struck RB’s appearance in the adoption action; and (2) because RB’s parental rights have been terminated, RB had no standing to object to or otherwise participate in the adoption. View "In re Adoption of SSO" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the district court’s order dismissing the Wyoming Department of Workforce Services Labor Standards Appeals Division (WFS) from Appellant’s petition for review of a WFS hearing examiner’s decision denying Appellant’s request for damages on his claim that the Wyoming Department of Corrections (DOC) discriminated against him based upon his advanced age. The district court granted WFS’s motion to dismiss, concluding that WFS was not a proper respondent to the petition for review. Several months later, the district court denied Appellant’s motion to amend his petition for review to substitute or join DOC as respondent in the action, ruling that it had no jurisdiction to act on Appellant’s motion to amend because the case was finally resolved upon WFS’s dismissal. On appeal, the Supreme Court concluded that it did not have jurisdiction over this matter because the district court’s order dismissing WFS was final and appealable. View "Schmitz v. State, Department of Workforce Services" on Justia Law

Res judicata barred Appellant from bringing this claim challenging the district court’s denial of his motion to correct an illegal sentence.Appellant pled guilty to burglary, felony larceny, and other crimes. Appellant later filed a motion for sentence reduction. The motion was denied. Appellant then filed a motion for sentence modification, which was also denied. Thereafter, Appellant filed a motion to correct an illegal sentence, arguing that the sentences he received for two crimes should have merged under double jeopardy principles because “the exact same conduct perpetrated against the same officer” was used to prove both crimes. The district court denied the motion. The Supreme Court affirmed, holding that Appellant failed to present any facts or circumstances demonstrating good cause for not raising his double jeopardy claim in earlier proceedings and, therefore, Appellant’s claim was barred by res judicata. View "Goetzel v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Appellant of attempted second-degree murder. The court held (1) there was no plain error or cumulative error in the district court’s instructions to the jury regarding sudden heat of passion, the definition of “malice” in the context of first-degree murder, the definition of “malice” in the context of second-degree murder, an aggressor’s right to use self-defense, and the duty to retreat before asserting the right of self-defense; and (2) the district court did not abuse its discretion by instructing the jury on the definitions of both “malice” and “maliciously.” View "Schmuck v. State" on Justia Law

For the reasons outlined in Barrera v. State, 403 P.3d 105 (Wyo. 2017) and those set forth in this opinion, the Supreme Court affirmed Defendant’s felony conviction for taking a controlled substance into a jail. The court held (1) the district court did not err in concluding that Defendant’s violated Wyo. Stat. Ann. 6-5-208 when he took a controlled substance into the county jail after being arrested; and (2) given the absence of citation to any pertinent authority, the court declined to reach the merits of Defendant’s argument that the district court and the State violated the Fifth Amendment prohibition against self-incrimination. View "Farnsworth v. State" on Justia Law

The Supreme Court reversed Appellant’s conviction for aggravated assault entered after a jury trial. The district court sentence Appellant to life in prison. The Supreme Court held (1) the prosecutor’s failure to comply with the court’s discovery order constituted misconduct; (2) the district court abused its discretion in denying Appellant’s motion to restrict witness testimony; (3) the prosecutor committed misconduct during closing argument; (4) Appellant was denied due process of law because he was required to wear a leg brace in the presence of the jury; and (5) because of the cumulative effect of these errors, Appellant was denied a fair trial. View "Black v. State" on Justia Law

The Supreme Court reversed the judgment of the district court granting summary judgment for Plains Tire & Battery, Co. in this case filed by Cindy and William Williams alleging that Plains was negligent in failing to maintain the area outside its store in a reasonably safe condition, leading Cindy to slip and fall. In granting summary judgment for Plains, the district court found that Plaintiffs failed to present a genuine issue of material fact as to whether Plains breached a duty to maintain its property in a reasonably safe condition. The Supreme Court disagreed and remanded the case, holding that Plaintiffs raised genuine issues of material fact. View "Williams v. Plains Tire & Battery Co., Inc." on Justia Law

The Supreme Court affirmed the juvenile court’s order denying Appellants’ motion to intervene in custody proceedings relating to their granddaughter, EHD. The court held (1) in light of the facts of this case, the juvenile court did not abuse its discretion in denying Appellants’ request to intervene; and (2) Appellants did not have standing to pursue their remaining arguments that the juvenile court abused its discretion in denying Appellants’ requests to be appointed to the multi-disciplinary team and in denying Appellants’ request that EHD be placed with them. View "MMH v. State" on Justia Law