This case concerned whether Wyoming's Office of Administrative Hearings had jurisdiction to appoint an attorney and award fees in a worker's compensation matter before the Division made a final determination denying benefits, any party objected in writing, or the case was referred for a contested proceeding. The facts involved an injured worker who sought counsel for a potential medical consultation dispute that never resulted in a denial or contested case filing, after which the hearing examiner granted fees over the Division's objection. The district court reversed the awards, concluding that the OAH acquires jurisdiction only upon proper objection and referral. The Wyoming Supreme Court affirmed in part and reversed in part, determining that the examiner lacked subject matter jurisdiction to appoint counsel or award fees without a contested case properly before it.
This case concerned a worker's compensation claim by Robert Roggenbuck, who had a significant preexisting back condition, for benefits after a work-related back injury at Laramie County School District No. 1 that allegedly required a third surgery. The Wyoming Supreme Court affirmed the Office of Administrative Hearings' award of benefits, holding that substantial evidence supported the finding of a material aggravation of the preexisting condition. The court reasoned that medical evidence, including a treating physician's attribution of 50 percent of the condition to the work injury, MRI comparisons showing deterioration, increased pain levels, and the timing of the need for surgery, established that the employment contributed to a material degree. The court also concluded that the hearing examiner's findings met the specificity requirements of the Wyoming Administrative Procedure Act by including basic facts underlying the conclusions.
The case involved a worker's compensation claim by Samuel Gonzales, who was injured while performing maintenance and setup work at a mobile home park. The administrative hearing examiner denied benefits, finding that the mobile home park industry fell under the statutory exclusion for real estate businesses, which are not considered extrahazardous employment requiring coverage. The court affirmed this decision, holding that the examiner's ruling was supported by substantial evidence and in accordance with law. It also rejected the constitutional challenges, concluding that the legislative classification excluding mobile home parks from mandatory coverage has a reasonable basis and does not violate equal protection or due process.
labor & employmentbusiness & regulatorycivil rights
The case concerned whether a 'household exclusion' in an automobile liability insurance policy issued by State Farm to the Pribbles limited coverage for bodily injury claims brought by daughter Heather Pribble against her mother Debora Pribble, who was at fault in a car accident. The district court granted summary judgment to State Farm, and the Wyoming Supreme Court affirmed. The court held that the exclusion language was plain and unambiguous, reducing coverage for household members only to the statutory minimum required by Wyoming law while leaving higher limits intact for other claims. It further ruled that the clause did not violate public policy, that the reasonable expectations doctrine did not apply to an unambiguous contract, and that State Farm was entitled to seek declaratory relief without owing attorney fees to the Pribbles.
The case involved the Hatch family suing State Farm Fire and Casualty Company for benefits under their home fire insurance policy after a 1987 house fire, as well as claims of bad faith and intentional infliction of emotional distress, following the insurer's denial based on an arson defense. After remand from a prior appeal, a jury found for State Farm on the policy benefits claim, and the trial court directed verdicts for the insurer and its agents on other issues including punitive damages. The Wyoming Supreme Court affirmed the judgment, holding that the trial court committed no error in its jury instructions on arson and damages, evidentiary rulings, or directed verdicts.
This case involved a worker, Jose M. Anaya, who suffered a back injury while employed by Holly Sugar Corp. and sought permanent total disability benefits under Wyoming's workers' compensation system after being awarded temporary benefits. The hearing examiner for the Workers’ Safety and Compensation Division granted him permanent partial disability benefits consisting of 7% for physical impairment and 20% for vocational loss, denying total disability including under the odd-lot doctrine. On appeal, the Wyoming Supreme Court affirmed the decision, holding that substantial evidence supported the examiner's findings on the impairment rating based on medical evaluations and on the vocational loss calculated from available job wages compared to pre-injury earnings. The court noted that Anaya failed to meet his burden of proof for total disability and that his deconditioning did not increase the physical impairment beyond 7%.