Richard J. Macy

In Garaman, Inc. v. Williams, a motel owner sued its architect for professional negligence and breach of contract after disputes over services on a construction project, while the architect counter-sued for unpaid fees. The district court granted a directed verdict dismissing the negligence claim, found no breach of contract or causation of delays, and entered judgment for the architect; the Wyoming Supreme Court affirmed. The court held that expert testimony is required to prove the applicable standard of care and breach in professional negligence claims against architects, that sufficient evidence supported the no-breach finding, and that the owner waived arbitration by litigating instead of seeking court enforcement of the clause.

proceduretorts & liabilitybusiness & regulatory

The case involved Jonathan Lee Roderick, a minor convicted in Wyoming district court of felony murder, aggravated burglary, and unauthorized use of a vehicle after he armed himself, entered the home of 85-year-old Calvin Dillon to steal, shot the victim twice, disposed of the body, and took the victim's truck. Roderick appealed on grounds including denial of a speedy trial, nondisclosure of exculpatory evidence, improper admission of his inculpatory statements, prosecutorial misconduct, improper opinion testimony on guilt, admission of victim photographs, and whether consecutive sentences for felony murder and the underlying felony should merge. The Wyoming Supreme Court affirmed the convictions and sentences in full, applying the Barker v. Wingo balancing test to conclude that most of the 181-day delay from information to trial was attributable to the defendant's numerous motions and that the remaining issues lacked merit under the record and governing legal standards.

criminal lawprocedure

The case involved Joe Johnson Co.'s petitions to the Wyoming State Board of Control seeking declarations of abandonment for several senior ground water rights held by S.Y. Ranches, Inc. and the Farmers' Home Administration, all drawing from the same aquifer as Johnson's junior-priority well. Johnson argued it had standing based on the potential benefit of fewer senior appropriators ahead of it, but presented no specific evidence or studies showing any tangible injury or effect on its own water use from possible reactivation of the wells. The Board denied standing, finding that enhancement of relative priority alone was insufficient without evidence of potential benefit or injury, and the Wyoming Supreme Court affirmed, deferring to the Board's expertise in groundwater matters and concluding the evidence did not support standing under the applicable statute. The court also noted the statutory requirements for standing in abandonment proceedings.

environmentproperty

This case concerned whether a construction worker fired after refusing (or delaying) a drug test was eligible for unemployment benefits or had been discharged for misconduct connected to his work. The Wyoming Supreme Court reversed the district court and held that the Unemployment Insurance Commission properly found the employee eligible for benefits. The court reasoned that the employer's evidence of misconduct was disputed, conclusory, and insubstantial, with no contemporaneous records to support claims of tardiness or erratic behavior, and that the statutory term "misconduct" must be construed narrowly to avoid forfeiting benefits except in clear cases. The Commission followed proper procedures in reviewing the appeals examiner's decision, and its findings were supported by substantial evidence.

labor & employment