Justia Wyoming Supreme Court Opinion Summaries

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The Supreme Court affirmed the district court’s decision affirming the decision of the Medical Commission, which sustained the Wyoming Workers’ Compensation Division’s termination of Sarah Morris’s temporary total disability (TTD) benefits. The Division terminated the TTD benefits after determining that Morris had reached maximum medical improvement. The Supreme Court held (1) the Commission appropriately determined that Morris had reached MMI and terminated her TTD benefits; and (2) substantial evidence existed to support the Commission’s decision that Morris’s injury to her right knee was not work-related. View "Morris v. State ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

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The district court did not abuse its discretion when it awarded primary physical custody of the parties’ daughter to Father.After Mother and Father divorced, Mother remarried and announced her intent to relocate to southern Colorado. Both parties sought primary physical custody of their daughter. The district court found that the child’s best interests were served by Father having primary custody. The Supreme Court affirmed, holding (1) the district court’s findings provided the court with a reasoned explanation for the district court’s decision to separate the child from her siblings; and (2) the district court did not err in admitting into evidence two letters written by Mother’s older child describing the child’s complaints about her relationship with Mother and recounting various instances of conflict. View "Paden v. Paden" on Justia Law

Posted in: Family Law
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The Supreme Court affirmed the district court’s dismissal of a complaint brought by the Town of Pine Bluffs alleging that Laramie County illegally taxed a day care center that the Town owned and operated. The Town sought an injunction under Wyo. Stat. Ann. 39-13-109(c)(i), alleging that the property was used for a governmental purpose and was therefore exempt under Wyo. Stat. Ann. 39-11-105(a)(v). The district court granted the County’s motion to dismiss, concluding that the Town should have exhausted administrative remedies before resorting to an injunction. The Supreme Court affirmed, holding that section 39-13-109(c)(i) did not provide the Town a remedy for an error in assessing the day care center and that it needed to resort to the administrative process instead. View "Town of Pine Bluffs v. Eisele" on Justia Law

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Due to deficiencies in this pro se appeal filed by Appellant, the Supreme Court summarily affirmed the district court’s dismissal of Appellant’s complaint. Appellant, a former project engineer at Sinclair Wyoming Refining Company, filed a complaint against certain Sinclair defendants, asserting fraud in the inducement and execution, breach of contract, and malicious destruction of property. The Sinclair defendants filed a motion to dismiss. Appellant filed timely to respond to the motion. The district court granted the motion to dismiss without a hearing. The Supreme Court summarily affirmed, holding that Appellant did not adequately comply with the Wyoming Rules of Appellate Procedure. View "Cor v. Sinclair Services Co." on Justia Law

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The Supreme Court affirmed the decision of the Teton County Board of County Commissioners granting Four Shadows, LLC a basic use permit (BUP) to use its property in Teton Village for temporary construction storage/staging. The court held (1) Appellants had an interest that was greater than the general public’s, giving them standing to maintain their appeal as persons aggrieved and adversely affected in fact by the Board’s decision to issue the permit; and (2) the Board’s decision to grant Four Shadows a BUP for temporary use of the property for construction storage/staging was not arbitrary, capricious, an abuse of discretion, or otherwise contrary to law. View "Tayback v. Teton County Board of County Commissioners" on Justia Law

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The Supreme Court affirmed Defendant’s convictions on one charge of domestic battery and one charge of strangulation of a household member. On appeal, Defendant argued that his convictions and sentences for both crimes violated his constitutional protections against double jeopardy because domestic battery is a lesser included offense of strangulation of a household member. The Supreme Court held that the district court did not commit plain error when it convicted and sentenced Defendant for the crimes of domestic battery and strangulation of a household member because Defendant’s two convictions arose from separate and distinct conduct, and therefore, Defendant failed to establish a double jeopardy violation. View "Drakeford v. State" on Justia Law

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The Supreme Court affirmed the district court’s ruling holding Husband in contempt and finding insufficient evidence to hold Wife in contempt. Both parties filed contempt motions alleging that the other party violated obligations imposed by both the divorce decree and a previous contempt ruling issued by the district court. In the first round of contempt motions filed by the parties, the district court found only Husband in contempt but ordered both parties to complete certain obligations. The Supreme Court held that there was no abuse of discretion in the district court’s ruling on the second contempt motions of Husband and Wife. View "Fowles v. Fowles" on Justia Law

Posted in: Family Law
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The Supreme Court affirmed Defendant’s convictions of three counts of sexual abuse of a minor in the second degree and one count of sexual abuse of a minor in the third degree for Defendant’s sexual abuse of the daughter of his girlfriend. Defendant appealed, arguing that his trial counsel provided ineffective assistance in multiple ways and that the district court committed reversible error. In affirming, the Supreme Court held (1) Defendant’s trial counsel was not ineffective in her representation of Defendant; and (2) there was no reversible error on the part of the district court. View "Woods v. State" on Justia Law

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The Supreme Court affirmed the juvenile court’s permanency order with regard to Mother’s child, an order that changed the permanency plan for the child from family reunification to adoption. The court held (1) despite the troubling delays in this neglect proceeding, Mother waived her due process and other claims relating to the change in permanency from reunification to adoption when she advocated the same change in permanency; and (2) the juvenile court did not err in refusing to designate the adoptive parents in the permanency order because determination of the adoptive parents is a matter for a separate proceeding. View "DM v. State" on Justia Law

Posted in: Family Law
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The Supreme Court affirmed the Medical Commission’s denial of Dennis Howe’s claim for permanent partial impairment (PPI) benefits for a work-related injury Howe suffered. The district court affirmed the decision of the Commission. In affirming the district court, the Supreme Court held (1) the Commission’s determination that Howe did not prove he was entitled to an increased impairment rating due to the result of chlorine exposure was supported by substantial evidence, and the Commission could have reasonably concluded as it did; and (2) the Commission’s decision was not arbitrary and capricious. View "Howe v. State, ex rel., Department of Workforce Services" on Justia Law