The Wyoming Supreme Court held that a post-competency trial setting complied with Rule 48 because the delay served the due administration of justice, Martinez had notice, and he suffered no substantial prejudice.
The Wyoming Supreme Court held that DFS shortcomings did not undermine a parental-rights termination where the mother knew the reunification requirements and left an independent statutory ground unchallenged.
The Wyoming Supreme Court upheld a hospital’s medical-malpractice defense verdict, ruling that a threshold special-verdict question about inappropriate touching was proper and required no additional definition.
The Wyoming Supreme Court held that outdated teacher-salary and inflation funding violated equal protection, but narrowed the trial court’s broader school-funding remedies.
The Wyoming Supreme Court affirmed an injunction barring an LLC manager from acting for the company, while holding that the trial court’s contract ruling remains preliminary.
The Wyoming Supreme Court held that a documented, multi-step search satisfied the diligence required for substituted service under the nonresident-motorist statute and affirmed a $154,661.25 default judgment.
The Wyoming Supreme Court affirmed a bench-trial judgment for Katya Hutton against the Estate of Robert P. Dykes, holding the district court did not abuse its discretion in implicitly denying Rule 37 sanctions—no prior order-to-show-cause hearing had been sought, the Estate declined an offered continuance, and trial testimony confirmed Hutton had produced everything in her possession—and that the court did not clearly err in finding the Estate failed to prove Hutton misappropriated condo rental income where the Marriott records it relied on were demonstrably unreliable.
The Wyoming Supreme Court affirmed a Park County divorce decree awarding Mother primary custody and $624,500 in equitable distribution, holding that Father’s W.R.C.P. 35 motion for psychological evaluations was untimely and lacked good cause, that the district court properly reached assets Father transferred to his nonprofit during the proceedings under the badges-of-fraud doctrine from Breitenstine, and that Father was barred by invited error from challenging the shared custody arrangement for the family dog.
The Wyoming Supreme Court affirmed a district court’s denial of a convicted shoplifter’s Rule 41(g) motion for return of seized property, holding that the State overcame the post-conviction presumption favoring return by presenting credible testimony that the items were likely stolen—and clarifying Wyoming’s burden-shifting framework for such motions for the first time in the context of alleged stolen property.
The Wyoming Supreme Court affirmed dismissal of a daughter’s declaratory judgment action seeking to establish that her late father’s interest in real property passed to his estate rather than to her mother by survivorship. The court held that a 2012 quiet title decree identifying the parents as “Husband and Wife” created a tenancy by the entirety under longstanding Wyoming common law, and that the 2023 codification of that presumption in Wyoming Statute § 34-1-140(b) merely clarified — rather than changed — pre-existing law.
The Wyoming Supreme Court affirmed a default judgment entered against a conservator who waited 190 days to answer counterclaims and then failed to move to set aside the default with any citation to W.R.C.P. 55(c) or 60(b), failed to identify a Rule 60(b) justification, and failed to address the three-factor good cause test. A vague oral request to set aside default, unsupported by legal authority, does not satisfy the moving party’s burden.
The Wyoming Supreme Court affirmed the district court’s denial of post-majority parental support for a physically disabled adult child. Although Son was found to be physically disabled, the court held the evidence supported the finding that he was capable of self-support where he received SSDI, performed daily living activities independently, and planned to pursue college on a merit scholarship.