Charles Stuart Brown

The case involves Roy Lee Engberg's appeal from the denial of post-conviction relief following his convictions for first-degree murder and armed robbery, for which a jury imposed a death sentence after finding multiple aggravating circumstances. The Wyoming Supreme Court divided its review between issues affecting the determination of guilt or innocence and those impacting the capital sentence, applying procedural waiver rules to bar most claims that could have been raised on direct appeal. The court affirmed the convictions, concluding that remaining issues such as failure to disclose a hypnotic session with a witness, ineffective assistance of counsel, and cumulative error did not demonstrate constitutional violations warranting reversal. However, it set aside the death sentence due to errors in the sentencing proceedings. The core reasoning emphasized that post-conviction relief is limited to constitutional claims manifesting a miscarriage of justice and is not a substitute for direct appeal.

criminal lawprocedure

This case concerns an appeal from a Wyoming district court's default divorce decree and a subsequent nunc pro tunc amendment, entered after the husband failed to comply with discovery orders and was held in contempt. The decree granted the wife a divorce, awarded her specific marital assets, and ordered the husband to pay $600,000 in alimony over time, with the obligation surviving his death. The Wyoming Supreme Court reversed, concluding that the default judgment improperly provided relief beyond the scope of the complaint without an evidentiary hearing or notice, that the alimony provision extending past death was unauthorized, and that the nunc pro tunc order was entered without required motion or notice to the opposing party.

family lawprocedure

This case arose when plaintiff James Waggoner was injured in a car collision while driving a 1972 Jeep Wagoneer loaned to him by Burman Motors, a General Motors dealership, as a temporary replacement while his new GM pickup was being repaired. Waggoner sued General Motors and Burman Motors, asserting claims of strict liability in tort, breach of implied warranty, and negligence based on alleged brake defects in the Jeep. The trial court granted summary judgment dismissing the strict liability and warranty claims, and a jury returned a verdict for the defendants on the negligence claim, finding that the other driver was solely at fault and that Waggoner suffered no compensable damages. The Wyoming Supreme Court affirmed, holding that Waggoner failed to present evidence of a defect sufficient to support the strict liability or warranty claims and that the jury's findings on negligence were supported by the record.

torts & liability

This case arose from a wrongful termination lawsuit brought by Brian Lorensen against his former employer, Lawrence-Allison & Associates West, Inc., after he was fired for allegedly hunting an antelope on a restricted federal reserve and transporting it in a government vehicle, in violation of his employment contract. The trial court applied collateral estoppel based on an earlier unemployment benefits administrative decision that found no misconduct and entered a default judgment on liability against the employer when its counsel withdrew on the eve of trial. The Wyoming Supreme Court reversed the default judgment, ruling that the trial court failed to properly inform itself before allowing withdrawal and imposing default, and remanded the case for further proceedings while questioning the application of collateral estoppel.

labor & employmentprocedure

This case involved a dispute over the foreclosure of a contractor's lien for architectural services on property owned by W.A.S., Inc., where the architect initially sued the owner and obtained a default judgment before the owner filed for bankruptcy. The bankruptcy filing triggered an automatic stay under federal law that halted further proceedings, including efforts to add the property's mortgage holders as defendants. After the bankruptcy was dismissed, the architect filed an amended complaint joining the mortgagees beyond the 180-day period set by Wyoming statute for commencing lien foreclosure actions. The Wyoming Supreme Court affirmed summary judgment in favor of the architect, holding that the bankruptcy stay applied to the lien action and that 11 U.S.C. § 108(c) tolled the state statute of limitations, making the amended complaint timely and establishing the lien's priority over the mortgage.

propertyprocedure

This case concerned a dispute over ownership of mineral rights (oil, gas, and other hydrocarbons) beneath streets and alleys in the Town of Moorcroft that had been dedicated to public use by the original plat filed by Lincoln Land Company in 1901. The abutting landowners sued for declaratory judgment to quiet title after the Town leased the minerals, claiming the rights passed to them through their lot purchases; the Town asserted ownership under a state statute treating the plat as a fee simple conveyance for public purposes, while Lincoln claimed it retained the minerals. The Wyoming Supreme Court held that the mineral rights remained with the original dedicator, Lincoln Land Company. It reasoned that the dedication created only a determinable fee in the surface estate for streets and alleys, without conveying the subsurface minerals, and that the subsequent warranty deeds to lot owners did not transfer or reserve any mineral interests from Lincoln. The Court declined to overturn its prior precedent in City of Evanston v. Robinson and applied general rules that a dedication or conveyance without explicit reservation passes only the intended surface rights.

property