Articles Posted in Wyoming Supreme Court

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Appellant pled guilty to six counts of second-degree sexual assault in 2000 and was sentenced to six consecutive life sentences. The current matter began when Appellant filed a Wyo. R. Crim. P. 36 motion requesting that the spelling of his surname in his judgment and sentence order be corrected from DELOGE to DeLoge or De Loge. The district court denied the motion, explaining that capitalization in the caption on court documents is not a clerical error. The Supreme Court affirmed, holding that the district court did not misspell Appellant’s name when it capitalized its letters, and therefore, there was no clerical error in the judgment and sentence. View "DeLoge v. State" on Justia Law

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Cheyenne Newspapers, Inc. (the Tribune-Eagle) submitted a public records request to Laramie County School District Number One (the School District) asking to inspect certain school board member email communications. The School District, in response, downloaded the emails to a compact disc and made the compact disc available to the Tribune-Eagle subject to a fee for the time the School District staff spent retrieving the records. Thereafter, the Tribune-Eagle filed a declaratory judgment action seeking a ruling that the Wyoming Public Records Act does not allow the School District to charge for access to electronic records when the request is for inspection of the records and not for a copy of the records. The district court concluded, as a matter of law, that the School District was entitled to the fees it charged the Tribune-Eagle for access to the requested emails. The Supreme Court affirmed, holding that Wyo. Stat. Ann. 16-4-202(d)(i) allows a public record custodian to charge for inspection of an electronic record if the inspect request requires production of a copy of the record, and reasonableness is the limitation on the costs that may be charged a public records applicant under the statute. View "Cheyenne Newspapers, Inc., v. Board of Trustees of Laramie County School District Number One" on Justia Law

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During the 2011-2012 school year, Plaintiff was a continuing contract teacher who worked for the Laramie County School District No. One. In spring of 2012, the District Superintendent gave Plaintiff notice that he proposed that Kinstler be terminated. On September 4, 2012, a hearing officer recommended that the District accept the Superintendent’s proposal. On September 17, 2012, the District’s Board of Trustees voted to accept the recommendation. Kinstler was paid his normal salary from August 15, 2012, the date he would have started to work, through the date that the Board acted on the recommendation to terminate him. Kinstler subsequently sued the District, asserting that the District failed to pay him the salary and value of benefits allegedly owed him for the 2012-2013 academic year. The district court partially granted Kinstler’s motion for summary judgment and entered an order with respect to his salary and benefits claim. The Supreme Court reversed and vacated the award, holding that because Kinstler’s termination was effective at the end of the 2011-2012 school year, he had no statutory right to compensation following that date. View "Laramie County Sch. Dist. v. Kinstler" on Justia Law

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In an effort to address a perceived drug and alcohol problem among its students, Goshen County School District No. 1 ("school district") adopted a policy requiring all students who participated in extracurricular activities to consent to random testing for alcohol and drugs. At issue was whether the district court properly granted summary judgment in favor of the school district where both parties agreed that there were no genuine issues of material fact but disagreed about whether the district court correctly applied the provisions of the Wyoming and United States Constitutions to the undisputed facts. The court held that appellants failed to demonstrate that the school district's policy subjected students to searches that were unreasonable under all of the circumstances and therefore, the policy did not violate Article 1, section 4 of the Wyoming Constitution. The court also held that the fact that the policy did not subject students to unreasonable seizures was, therefore, determinative of appellants' equal protection claim as well. The court further held that appellant had not demonstrated infringement of due process rights where appellants' speculation that judicial review might be denied in the future was insufficient to support a due process claim now. Accordingly, because appellants failed to prove that the school district's policy was unconstitutional, there was no basis for their claim that they were entitled to a permanent injunction or for their claim that the district court erred in granting summary judgment.