Justia Government & Administrative Law Opinion Summaries

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

The Supreme Court affirmed the order of the Wyoming Public Service Commission (PSC) administering the Wyoming Universal Service Fund (WUSF) for the 2020-2021 fiscal year, holding that the PSC's order was lawful.It issue was the interplay between the Federal Universal Service Fund (FUSF) and the WUSF. The PSC's order adopted a methodology for calculating WSFU disbursements that treated a portion of the 2019 support each Wyoming telecommunications company received from the federal Alternative Connect America Cost Model programs as contributions from the FUSF. Union Telephone Company filed a petition for review, asserting that the order rejected existing law and materially prejudiced Union. The Supreme Court affirmed, holding (1) collateral estoppel did not bar the PSC from adopting a WUSF calculation methodology that considered the A-CAM funds to be FUSF contributions; (2) the PSC's order was lawful; and (3) Union's remaining claims of error were unavailing. View "Union Telephone Co. v. Wyoming Public Service Commission" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Appellants' petition for review of a decision of the Board of County Commissioners, Lincoln County under Wyo. R. App. P. 12 and Wyo. Stat. Ann. 16-3-114, holding that the district court abused its discretion by sanctioning Appellants with dismissal of their petition for review.The district court dismissed Appellants' petition, determining that Wyo. R. App. P. 2.06 required a transcript to be filed within sixty days of the filing of the petition for review of agency action and that no transcript was filed. The Supreme Court reversed, holding (1) the district court misstated and misapplied Rule 2.06; (2) the Board failed to transmit the record as required by Rule 12.07; and (3) because the Board, not Appellants, had the responsibility to transmit the entire record to the district court, the court abused its discretion by dismissing the action. View "Depiero v. Board of County Commissioners, Lincoln County" on Justia Law

The Supreme Court affirmed the judgment of the Medical Commission Panel denying Appellant's application for additional benefits and an increase to her impairment rating, holding that the Medical Panel's decision was not arbitrary, capricious, or otherwise not in accordance with the law.In 2014, Appellant suffered a workplace injury. In 2019, Appellant applied for additional benefits, including surgery for carpal tunnel syndrome, and an increase to her impairment rating. The Medical Panel denied both requests, determining (1) Appellant's carpal tunnel syndrome was not related to her workplace injury, and (2) Appellant's claim for an increased impairment rating was unsubstantiated. The Supreme Court affirmed, holding that the Medical Panel's ultimate determinations were supported by substantial evidence and were not arbitrary, capricious, or otherwise not in accordance with law. View "Reichenberg v. State, ex rel., Department of Workforce Services" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Medical Commission upholding the denial of Appellant's request for benefits, holding that there was substantial evidence to support the Commission's denial of coverage.In 2007, Appellant suffered a compensable injury to her left knee. More than a decade later, Appellant submitted requests to the Department of Workforce Services, Workers' Compensation Division to cover treatment for her right knee, ankles and back and further applied for permanent total disability (PTD) benefits. The Division denied both requests, and the Commission affirmed the ruling. The Supreme Court affirmed, holding that that there was substantial evidence to support the Commission's findings that (1) Appellant's right knee, ankle, and back injuries were not second compensable injuries; and (2) Appellant did not qualify for PTD benefits under the odd lot doctrine. View "Ross v. State, ex rel., Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court affirmed the decision of the Office of Administrative Hearings (OAH) upholding the decision of the Wyoming Department of Transportation (WYDOT) suspending Defendant's driver's license and operating privileges pursuant to Wyo. Stat. Ann. 31-6-102(e), holding that the OAH reasonably concluded as it did.Defendant was arrested for driving under the influence of alcohol. Because a breathalyzer test indicated that Defendant had a blood alcohol concentration greater than .08% the WYDOT suspended Defendant's driver's license. The OAH upheld the suspension. The Supreme Court affirmed, holding that substantial evidence supported the OAH's finding that law enforcement did not interfere with Defendant's right to obtain an independent chemical test under Wyo. Stat. Ann. 31-6-102(a)(ii)(C) and 31-6-105(d). View "Flauding v. State ex rel. Wyoming Department of Transportation" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the determination of the Medical Commission Hearing Panel that Scott Triplett failed to meet his burden to show entitlement to a right hip replacement, holding that the Medical Panel's decision was neither arbitrary or capricious.The Medical Panel determined that Triplett did not meet his burden of proof to establish that the hip replacement surgery was a reasonable and necessary medical treatment for any injury related to his work injury. The district court affirmed. The Supreme Court affirmed, holding that the Medical Panel's determination was supported by substantial evidence and was not arbitrary, capricious, or otherwise contrary to law. View "Triplett v. State, ex rel. Department of Workforce Services" on Justia Law

The Supreme Court affirmed the judgment of the district court reversing in part and affirming in part the decision of the Wyoming Board of Medicine to suspend Dr. Rebecca Painter's medical license, holding that the district court did not err.The Board appointed two members (Petitioners) to file a complaint and petition alleging that Painter had violated certain provisions of the Wyoming Medical Practice Act, Wyo. Stat. Ann. 33-26-101 through -703. After a contested case hearing, the Board terminated Painter's license upon finding that Painter had exploited her professional relationship with a patient and the patient's family and improperly terminated the physician-patient relationship. The Board then assessed costs and fees against Painter. The district court affirmed some violations, reversed other violations, reversed the Board's assessed fees and affirmed all other costs. The Supreme Court affirmed, holding (1) the contested case hearing procedure did not violate Painter's due process rights; (2) the Board's finding that Painter exploited her professional relationship with the patient was supported by clear and convincing evidence; and (3) the Board's finding that Painter improperly terminated the physician-patient relationship was supported by substantial evidence. View "Hallingbye ex rel. Wyoming Board of Medicine v. Painter" on Justia Law