William A. Riner

This case involved plaintiffs seeking to enjoin Wyoming state water officials from interfering with their claimed water rights on lands originally allotted under 19th-century treaties creating the Wind River Indian Reservation and later conveyed to non-Indian owners after partial cession of reservation lands. The trial court denied the injunction after finding that the plaintiffs had not established superior rights over other users. On appeal, the Wyoming Supreme Court affirmed, holding that the plaintiffs failed to prove specific quantities of water used or irrigated acreage as required for injunctive relief, that their rights had not been formally adjudicated, and that the evidence was insufficient to support an order against the officials. The court noted that any rights should be determined through proceedings before the state Board of Control rather than by injunction in this action.

propertyfederal powerprocedure

In State v. Paulas, the defendant was charged with arson for allegedly setting fire to a haystack valued at $25 or more belonging to another person in Platte County, Wyoming, on May 16, 1953. A jury convicted him after a trial in which he represented himself, based primarily on circumstantial evidence including footprints found near the stack and leading toward his residence across a traveled gravel road. The Wyoming Supreme Court reversed the conviction and ordered a new trial, holding that the trial court's jury instruction on circumstantial evidence was inadequate because it failed to require that the facts exclude every reasonable hypothesis of innocence other than guilt. The court further concluded that the evidence was legally insufficient to prove the defendant's guilt beyond a reasonable doubt, as the tracks could not be positively traced across the road and other explanations remained possible.

criminal law

The case involved a landowner who trapped and killed beaver damaging her property, stored the pelts, and then sued the Wyoming Game and Fish Commission along with various officials after they seized the pelts, seeking actual and punitive damages. The central issue was whether a state agency could be sued for tort damages without the state's consent. The court affirmed the lower court's ruling sustaining a demurrer, holding that such a suit against an agency performing a governmental function does not lie absent legislative consent. This decision rested on longstanding Wyoming precedents interpreting the state constitution to require explicit legislative authorization for suits against the state or its agencies.

procedurepropertytorts & liability

This case concerned the estate of Fred Jansen, who died intestate in 1952 leaving ten children as heirs and an estate valued at about $36,000. The district court ruled that a $6,211.91 bank account Fred had transferred into a joint account with his son Elmer Jansen and Elmer's wife shortly before his death constituted an advancement that must be charged against Elmer's share of the inheritance. The Wyoming Supreme Court reversed that ruling on appeal. It held that the presumption of an advancement arising from a parent's transfer of property to a child is overcome by evidence of contrary intent, and the record here—including Elmer's long unpaid management of the father's properties and the circumstances of the transfer—showed overwhelmingly that Fred did not intend the joint account as an advancement. The matter was remanded for entry of an order consistent with that conclusion.

family lawproperty

The case involved Leo Wagner's conviction in Casper municipal court for driving a vehicle while under the influence of alcohol, resulting in a $100 fine. Wagner appealed to the district court but took no action to prosecute the appeal over multiple court terms. The city moved to dismiss the appeal for failure to diligently prosecute, the district court granted the motion, and Wagner appealed that dismissal. The Wyoming Supreme Court affirmed the dismissal, holding that the statutory speedy-trial discharge provision (W.C.S. 1945 § 10-1313) does not apply to appeals from municipal-court convictions already obtained, and that a defendant must affirmatively request a trial de novo rather than passively await dismissal.

criminal lawprocedure

This case involves a workers' compensation claim under Wyoming law by Leo Carey, a truck driver employed by Schroeder Mining Company, who was injured by lightning while in the company office after turning in his time card at the end of his shift. The lightning entered through the ungrounded electrical system connecting the office to a high-voltage government line, which lacked proper grounding, lightning arresters, or other safeguards despite prior incidents of storm damage to company equipment. The trial court denied benefits, ruling the injury was an act of God that did not arise out of the employment. The Wyoming Supreme Court reversed, holding that Carey's required presence at the office exposed him to a heightened risk from lightning due to the employer's deficient electrical setup, which was not shared by the general public, and thus the injury was compensable. The court remanded for further proceedings on the extent of disability and an award.

labor & employment