Justia Government & Administrative Law Opinion Summaries

In 2013, Bryan Skoric, the Park County Attorney, reconsidered the extent of his office’s participation in civil commitment proceedings and decided not to continue to participate in emergency detention hearings under Wyo. Stat. Ann. 25-10-109 or to appear and prosecute the case in chief at involuntary hospitalization hearings under Wyo. Stat. Ann. 25-10-110. Appellants, the West Park Hospital District and Yellowstone Behavioral Health Center, filed a petition for writ of mandamus asking the district court to compel Skoric to proceed in the same way as he had in the past. The district court denied Appellants’ application for the writ. The Supreme Court affirmed, holding (1) the statutes in question do require a county attorney’s office to participate in civil commitment proceedings; but (2) the statutes are ambiguous, and therefore, extraordinary relief was not warranted when Appellants filed their petition. View "State ex rel. West Park Hosp. Dist. v. Skoric" on Justia Law

In 2007, Appellant suffered a work-related injury to his right hip. In 2009, the Wyoming Workers’ Safety and Compensation Division denied Appellant’s requests for testing and treatment of pain in his back on the grounds that the requests were unrelated to Appellant’s work injury. The Office of Administrative Hearings (OAH) reversed and ordered that one additional test be performed to determine whether Appellant’s back problems were associated with his work injury. After the results of the test came back normal, the hearing examiner ordered that Appellant was not entitled to further benefits for his back. The district court affirmed. The Supreme Court affirmed as modified, holding (1) substantial evidence supported the OAH decision that Appellant did not satisfy his burden of proving additional testing and treatment of his back were related to his work injury; but (2) future treatment associated with the original hip injury could be submitted for administrative review. View "Delacastro v. State ex rel., Wyo. Workers' Safety & Comp. Div." on Justia Law

Appellant received worker’s compensation benefits in 1996 and 2004 for work-related injuries to his back. In 2008 and 2011, Appellant underwent surgeries to treat a herniated disc in his low back. The Wyoming Workers’ Compensation Division denied Appellant’s application for benefits to cover the two surgeries and any other expenses incurred after 2005. On appeal, Appellant contended that the herniated disc was a direct result of his 1996 and 2004 injuries and was therefore a second compensable injury. The Office of Administrative Hearings (OAH) upheld the Division’s denial of benefits. The district court affirmed. The Supreme Court affirmed, holding that the OAH’s decision upholding the denial of benefits was supported by substantial evidence and not contrary to the overwhelming weight of the evidence. View "Bodily v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Recently-adopted regulations required companies engaged in hydraulic fracturing to disclose the chemical compounds used in the process to the Wyoming Oil and Gas Conservation Commission. Appellants sought from the Commission disclosure of certain chemicals used in several companies’ hydraulic fracturing products. The Commission Supervisor refused to disclose the information, concluding that it was exempt from public disclosure as trade secrets under the Wyoming Public Records Act (WPRA). Appellants sought review of the Supervisor’s decision. The district court affirmed. The Supreme Court reversed and remanded, holding (1) the district court did not have the authority to evaluate the Supervisor’s decision using an administrative standard of review, and rather, should have used the procedures specified in the WPRA; and (2) the definition of a trade secret under the WPRA is the one articulated by federal courts under the Freedom of Information Act. View "Powder River Basin Res. Council v. Wyo. Oil & Gas Conservation Comm'n" on Justia Law

In 2005, Tara Kobielusz began working for Circle C Resources, which provides living assistance for persons with developmental disabilities. In 2010, Kobielusz began working for Circle C as a “host family provider.” That same year, Kobielusz fell and broke her ankle when entering Circle C’s office to pick up Kobielusz’s clients from their day habilitation program. The Workers’ Safety and Compensation Division found Kobielusz had suffered a compensable injury. Circle C requested a contested case hearing before the Office of Administrative Hearings (OAH), arguing that Kobielusz was not an employee, but rather, an independent contractor. The OAH upheld the Division’s determination. The district court affirmed. The Supreme Court affirmed, holding that Kobielusz did not qualify as an “independent contractor” under the meaning of the Worker’s Compensation Act. View "In re Worker's Comp. Claim of Kobielusz" on Justia Law

Appellant first received benefits for work-related injuries he received to his knees in 1992. In 2009, Appellant requested preauthorization to perform total knee replacement on both knees. The Workers’ Safety and Compensation Division denied the request and also denied payment of continued treatment of Appellant’s knees, concluding that the treatment and total knee replacements were not associated with the 1992 work injury. After a contested case hearing, the Medical Commission upheld the Division’s decision. The Supreme Court affirmed, holding (1) the Medical Commission did not commit prejudicial error during the hearing by admitting into evidence, over Appellant’s objection, three exhibits; and (2) substantial evidence supported the Commission’s decision. View "Johnson v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Appellant was originally injured in 1975 while working for his employer. Appellant’s injuries resulted in the amputation of his right leg, below the knee. The Wyoming Workers’ Safety and Compensation Division paid a number of benefits over the years. Years later, Appellant began receiving chiropractic treatment, including cold laser therapy, from Utah Spine and Disc Clinic in Murray Utah. Appellant sought reimbursement for travel to and from the clinic. In 2011, the Division denied Appellant’s request for reimbursement because (1) traditional types of chiropractic care, manipulation, and traction could have been obtained at a location in Wyoming closer to Appellant’s home; and (2) cold laser therapy was considered experimental and was therefore not a covered treatment for which the Division would pay travel expenses. The Supreme Court affirmed, holding that the Division did not err in its interpretation of the applicable Wyoming statutes, and the Division’s decision contained adequate findings of fact, which findings were supported by substantial record evidence. View "Birch v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

In 1999, Appellant experienced a workplace injury to her back, for which she received benefits awarded by the Wyoming Workers’ Safety and Compensation Division (“Division”). In 2008, while employed in Nebraska, Appellant suffered a second workplace injury. Appellant filed a worker’s compensation claim in Nebraska relating to her 2008 injury and subsequently settled that claim. In 2010, Appellant sought payment for prescription medication for headaches she was experiencing, claiming that the treatment was related to her 1999 injury. The Division denied benefits, concluding that the treatment and medications were unrelated to the original compensable 1999 injury. After a contested case hearing, the Office of Administrative Hearings upheld the Division’s denial of benefits. The district court affirmed. The Supreme Court affirmed, holding that substantial evidence supported the hearing examiner’s finding that there was no causal connection between Appellant’s headaches and her 1999 workplace injury. View "Landwehr v. State ex rel. Workers' Safety & Comp. Div. " on Justia Law

The Wyoming Department of Transportation notified Appellant that his commercial driver’s license would be disqualified for one year on the basis that Appellant had driven a commercial vehicle with a blood alcohol concentration of 0.04 percent or greater. Appellant requested a contested case hearing. A hearing examiner upheld the Department’s decision. The district court affirmed the license disqualification. On appeal, Appellant contended that the hearing examiner’s findings of fact were unsupported by substantial evidence. The Supreme Court affirmed, holding (1) substantial evidence supported the hearing examiner’s decision; and (2) any errors regarding the hearing examiner’s findings of fact were harmless. View "McCallie v. State ex rel. Dep't of Transp." on Justia Law

In 1994, Appellant suffered modest physical injuries while working as a psychiatric aide at the Wyoming State Hospital. Four years later, Appellant was denied permanent total disability (PTD) benefits. Appellant continued seeking medical treatment. Appellant reapplied for PTD benefits in 2009, but the Wyoming Workers’ Safety and Compensation Division denied her claim. After a case hearing, a panel of the Medical Commission denied the subsequent application for PTD benefits, concluding that Appellant’s only disabling condition was psychological and not related to any compensable physical injury. The district court affirmed. The Supreme Court affirmed, holding that the Commission reasonably concluded that Appellant did not establish entitlement to PTD benefits under the Wyoming Workers’ Compensation Act or the odd lot doctrine, and the Commission’s conclusions were in accordance with applicable law. View "In re Worker's Comp. Claim of Hathaway" on Justia Law