Wyoming v. WEA — School funding model partly unconstitutional
The Wyoming Supreme Court held that outdated teacher-salary and inflation funding violated equal protection, but narrowed the trial court’s broader school-funding remedies.
The Wyoming Supreme Court held that outdated teacher-salary and inflation funding violated equal protection, but narrowed the trial court’s broader school-funding remedies.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 held that time spent jailed on independent Iowa charges did not count toward a Wyoming sentence and declined to review a later counsel order that was not identified in a notice of appeal.
The Wyoming Supreme Court held that jail time already credited to a probation-revocation sentence did not have to be credited again in two separate felony cases.
The Wyoming Supreme Court held that Brown waived a new dog-sniff suppression theory and upheld the admission of coded drug-related messages under Rule 404(b).
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 witness intimidation is a specific-intent conduct offense, affirmed Walker’s convictions, and remanded to correct illegal misdemeanor sentences.
The Wyoming Supreme Court held that asking a child to touch an adult’s exposed genitals can support attempted sexual exploitation under the statute’s masturbation category.
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 the denial of a new trial because substantial independent evidence defeated prejudice from counsel’s alleged errors.
The Wyoming Supreme Court affirmed civil-contempt sanctions after a former husband frustrated a court-ordered joint tax filing, clarifying willfulness, inability to comply, and compensatory remedies.
The Wyoming Supreme Court held that digital penetration and use of a sexual device qualify as explicit sexual conduct under the child-exploitation statute and upheld an aggregate 21-to-30-year sentence.
The Wyoming Supreme Court upheld a bicycle stop based on an objectively reasonable factual mistake and refused to review issues not specifically preserved in a conditional plea.
Wyoming’s high court held that vulnerable-adult exploitation spanning two counties could be tried in Converse County and affirmed restitution for clothing made inaccessible by the crime.
The Wyoming Supreme Court affirmed Steven Randall Marler’s convictions on eight counts of sexual abuse and six counts of battery against children in his care, holding that the district court properly admitted broad Rule 404(b) “other acts” evidence of grooming rituals and a fear-based disciplinary regimen, that a victim’s collateral lie to a jail guard was excludable without violating the Confrontation Clause, that a rule-of-completeness claim was waived by failure to make an offer of proof, and that brief prosecutorial questioning about a victim’s father’s suicide did not constitute plain-error misconduct.
The Wyoming Supreme Court affirmed the termination of both parents’ parental rights to three children under Wyo. Stat. Ann. § 14-2-309(a)(v), holding that the statute—requiring only that the child has been in foster care for 15 of the past 22 months and that the parent is unfit—does not impose a reasonable-reunification-efforts requirement; that DFS’s documentation gaps did not reach the structural failure level required by MB; and that clear and convincing evidence of parental unfitness supported the district court’s termination order.
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 probation revocation, holding that the district court erred by determining willfulness during the adjudicatory phase rather than the dispositional phase—a clear violation of Wyoming’s two-part revocation framework—but that the error did not constitute plain error because Smith suffered no material prejudice: he presented his willfulness arguments before the court’s finding and again at disposition, and an independently established, uncontested violation independently supported revocation.
The Wyoming Supreme Court unanimously affirmed the denial of Christopher Campbell’s motion to suppress evidence seized from his Evanston residence, holding that Deputy Barker’s search-warrant affidavit established probable cause under the totality-of-circumstances test. The court rejected Campbell’s paragraph-by-paragraph critique of the affidavit as methodologically improper: Wyoming law requires courts to evaluate the affidavit as a whole, not in piecemeal fashion. Viewed in its totality, a convergence of circumstantial links—a matching U-Haul seen at the residence, receipts tying an associate to both the truck and the address, Arizona connections shared by the stolen vehicle and the occupants, and matching tire tracks—established the required nexus between the evidence sought and the place to be searched.
The Wyoming Supreme Court affirmed Albany County’s 2023 amendments to its Aquifer Protection Overlay Zone — including a 35-acre minimum lot size within the Casper Aquifer recharge area — holding that counties may use general zoning authority under Wyo. Stat. Ann. § 18-5-201 to protect groundwater without displacing WDEQ’s water quality jurisdiction. The court also established, for the first time in a published Wyoming opinion, that the arbitrary and capricious standard of review applies to all agency legislative action (rulemaking) under WAPA, resolving a gap left open by Bienz v. Board of County Commissioners, 2024 WY 102. Justice Hill dissented on authority, arguing the EQA grants WDEQ exclusive jurisdiction over water quality regulation.
The Wyoming Supreme Court affirmed a finding that a mediated settlement email was unenforceable because the parties never agreed on whether ditch access would be implemented through an easement, license, or other interest and never specified whether a storage restriction would run with the land or remain a personal obligation, leaving essential terms undefined and creating at most an agreement to agree.
The Wyoming Supreme Court reversed and remanded a criminal case in which the district court ordered the defendant to sell a vehicle and deposit the proceeds as a condition of maintaining his public defender appointment. The court held that the subsequent guilty plea did not waive the challenge because the issue was unrelated to guilt or conviction, and that the district court exceeded its statutory authority under Wyoming’s public defender reimbursement statute by compelling a pre-sentencing forced asset liquidation.
The Wyoming Supreme Court reversed a contempt order against the Wyoming Boys’ School for refusing to admit an alleged delinquent juvenile before adjudication. The court held that Wyoming law expressly prohibits pre-adjudication placement at WBS, which is a reformatory for adjudicated delinquents — not a juvenile detention facility — and that the juvenile court abused its discretion by ordering such placement. All three exceptions to the mootness doctrine applied, allowing the court to reach the merits despite the case having been resolved below.
The Wyoming Supreme Court summarily affirmed a divorce decree granting Mother sole custody of ten children and assigning nearly all marital debt to incarcerated Father, holding that Father’s nine-issue opening brief contained no cogent argument — just general legal principles with no case-specific analysis — and that his reply brief improperly raised four new issues while failing to respond to Mother’s arguments. Attorney fees under W.R.A.P. 10.05 were declined as a matter of discretion, but costs were awarded.
The Wyoming Supreme Court affirmed the Medical Commission’s denial of workers’ compensation benefits to a claimant who developed pancreatitis after a Depakote dosage increase prescribed for migraines caused by his 2014 compensable head injury, holding that a numerical majority of supporting experts does not satisfy the preponderance-of-the-evidence standard and that the Commission acted within its discretion in rejecting an expert’s causation opinion premised on a dosing timeline contradicted by the claimant’s own testimony.