Justia Government & Administrative Law Opinion Summaries

The Supreme Court affirmed the decision of the Medical Commission Hearing Panel (Commission) upholding that decision of the Wyoming Workers' Compensation Division denying Claimant's request for permanent total disability (PTD) benefits for a work-related injury that Claimant asserted made him unemployable, holding that the Commission's decision was supported by substantial evidence and was unaffected by any error of law.At issue was Claimant's request for PTD benefits for a work-related back injury Claimant suffered in 2002. The Division denied Claimant's application for PTD benefits, and the Commission upheld the Division's denial of PTD benefits. The Supreme Court affirmed, holding that the Commission correctly determined that Claimant did not meet his burden of proving he was entitled to PTD benefits under the odd lot doctrine. View "Genner v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Wyoming State Board of Equalization (Board) affirming the tax assessment set forth by the Wyoming Department of Revenue (DOR) imposing severance and ad valorem property taxes on the waste mine gas (WMG) captured and used by Solvay Chemicals, Inc., holding that there was no error.Solvay used the WMG released from its trona mining operations to help fuel its soda ash processing plant during the years 2012 through 2015. The DOR imposed severance and ad valorem taxes on the WMG during those years. Solvay objected, arguing that the WMG was not taxable under the severance or ad valorem tax statutes. The Supreme Court affirmed, holding that Solvay failed to show the DOA and DOR improperly valued the WMG for production years 2012-2015. View "Solvay Chemicals, Inc. v. Wyoming Dep't of Revenue" on Justia Law

The Supreme Court affirmed the ruling of the State Board of Equalization affirming the decision of the Wyoming Department of Revenue disallowing a deduction of bagging costs from the taxable value of its bagged soda ash, holding that Solvay Chemicals, Inc. was not entitled to deduct bagging costs from the taxable value of soda ash.In 2013-2015, Solvay deducted its soda ash bagging costs from the taxable value of the bagged soda ash it sold. The Department determined that Wyo. Stat. Ann. 39-14-303(b) did not entitle Solvay to a separate deduction for bagging costs, and the Board and district court affirmed. The Supreme Court affirmed, holding that the Board did not err in determining that the Department's interpretation of section 39-14-303(b)(ii) was not erroneous or contrary to the plain language of Wyo. Stat. Ann. 39-14-303(b)(iv). View "Solvay Chemicals, Inc. v. Wyoming Department of Revenue" on Justia Law

The Supreme Court affirmed the judgment of the juvenile court ordering the permanency plan for minor siblings BP and CS be changed from reunification to adoption, holding that the juvenile court did not abuse its discretion.The Department of Family Services (DFS) recommended changing the permanency plan for BP and CS to adoption. After a permanency hearing, the juvenile court issued an order changing the permanency plan to adoption and relieving DFS from further reunification efforts, finding that DFS established that it had made reasonable efforts to reunify the family. The Supreme Court affirmed, holding that the juvenile court did not abuse its discretion when it concluded that DFS made reasonable efforts to reunify Mother with CS and BP and changed the permanency plan for reunification to adoption. View "NP v. State" on Justia Law

The Supreme Court reversed the decision of the district court determining that the procedures leading to the dismissal of Petitioner from the City of Rawlins Fire Department violated Petitioner's right to due process and ordering her to be reinstated with back pay, holding that the Rawlins Fire Department Civil Service Commission's decision terminating Petitioner's employment was supported by substantial evidence in accordance with law.The Commission concluded that the reason for Petitioner's discharge was "sufficient and established" pursuant to Wyo. Stat. Ann. 15-5-112(b) because Petitioner violated Civil Service Commission Rules 21.3 and 2.7 and ordered Petitioner's employment be terminated. In so concluding, the Commission explicitly rejected Petitioner's argument that she was denied due process. The trial court reversed, finding that Petitioner's due process rights were violated. The Supreme Court reversed, holding (1) Petitioner was afforded due process prior to her discharge by the Commission; and (2) the Commission's decision was supported by substantial evidence and was not arbitrary or capricious. View "City of Rawlins v. Schofield" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the Wyoming Board of Equalization (Board) concluding that WPX Energy Rocky Mountain, LLC was entitled to deduct some of its "reservation fees," holding that the Board erred in interpreting the plain language of Wyo. Stat. Ann. 39-14-203(b)(vi)(C) in its decision.At issue on appeal was whether and to what extent WPX was entitled to deduct "reservation fees" under the "netback" severance tax valuation method, section(vi)(C), for natural gas production years 2013-2015. The Board concluded that WPX was entitled to deduct some of its reservation fees. The Supreme Court reversed in part, holding (1) the statute allows WPX to fully deduct its pipeline reservation fees for months when some but not the full reserve capacity of gas was transported on that pipeline; (2) the statute does not allow WPX to deduct its Bison Pipeline reservation fees for months when it shipped no gas on the pipeline; and (3) the Board's conclusion that WPX cannot deduct any portion of its Bison Pipeline reservation fees it used to recoup pipeline construction costs was contrary to the plain language of the statute and the Bison agreement. View "Wyo. Department of Revenue v. WPX Energy Rocky Mountain, LLC" on Justia Law

The Supreme Court affirmed the decision of the district court reversing the decision of the Office of Administrative Hearings (OAH) awarding Plaintiff permanent partial disability benefits (PPD) after she injured her back and left hip while working as a registered nurse, holding that the district court did not err.The OAH awarded Plaintiff benefits after finding that she had made a tangible effort to seek suitable employment given her health, education, training, and experience. The district court reversed, finding that Plaintiff did not present sufficient evidence that she actively sought work and did not present expert medical testimony showing she was incapable of working. The Supreme Court affirmed, holding that the OAH decision was not supported by substantial evidence because Plaintiff did not establish by a preponderance of the evidence that there was no suitable work given her health. View "McBride v. State, ex rel. Department of Workforce Services" on Justia Law

The Supreme Court affirmed the judgment of the Wyoming Workers' Safety and Compensation Division denying coverage for Claimant's thoracic spine treatment, holding that the Medical Commission's decision was supported by the hearing evidence.After the Division denied Claimant's compensation coverage for his thoracic spine treatment Claimant appealed. The Compensation Commission upheld the denial of coverage following a contested pain hearing, and the district court affirmed. The Supreme Court affirmed, holding (1) the record contained substantial evidence to support the Commission's findings that Claimant's thoracic spine injury was unrelated to his work-related accident; and (2) Claimant failed to meet his burden of proving that his thoracic spine evaluation and treatment were compensable under the "rule out" doctrine. View "Hart v. State of Wyoming, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Office of Administrative Hearings (OAH) upholding the Wyoming Workers' Compensation Division's denial of Appellant's request for an endless pool to treat his work-related injury, holding that there was no error.Appellant requested that the Division preauthorize the purchase of a small pool with an underwater treadmill known as an endless pool to help him manage his medical condition. The Division denied the request in part, and the OAH upheld the determination. The district court affirmed. The Supreme Court affirmed, holding (1) the OAH had authority to decide this case; and (2) the OAH properly determined that Appellant was collaterally estopped from relitigating his right to an endless pool for treatment because the issue was fully decided in an earlier OAH order denying the claim. View "McCallister v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court affirmed the judgment of the district court modifying an arbitration award compensating Appellant, a rancher, for calf damage he sustained during the 2018 grazing season as a result of grizzly bear predation, holding that the district court did not err in modifying the award.Appellant reported the number of his calves dead from grizzly bear predation to the Wyoming Game and Fish Department and submitted a claim requesting that the Department compensate him $349,730. The Department rejected the damage claim and agreed to compensate Appellant $61,203. After the Commission affirmed Appellant requested arbitration. The arbitrators awarded Appellant $266,685 for his calf damage. The Department filed a motion to modify the arbitration award. The district court granted the motion and modified the award to reflect the amount of $61,203. The Supreme Court affirmed, holding that the arbitrators made an award on a matter not submitted to them and thus did not follow the law. View "Longwell v. Wyoming Game & Fish Department" on Justia Law