Justia Government & Administrative Law Opinion Summaries

The Supreme Court affirmed the decision of the district court upholding the decision oft he Office of Administrative Hearings (OAH) denying workers' compensation benefits to Appellant, holding that a previous order by the OAH was not a final, appealable order and that collateral estoppel was not applicable.Appellant filed for workers' compensation benefits after his leg was amputated below the knee. The Department of Workforce Services, Workers' Compensation Division (the Division) denied the claim. Appellant appealed, but while the contested case hearing was pending the Division withdrew its denial of benefits. In response, the OAH issued an order vacating the hearing and directing the Division to award workers' compensation benefits. The Division issued a redetermination in favor of Appellant. Appellant's employer objected, and after a contested case hearing, OAH denied workers' compensation benefits. The district court upheld the OAH decision denying benefits. On appeal, Appellant claimed that the first OAH order was a final appealable order awarding benefits and that his employer was collaterally estopped from objecting to the Division's redetermination awarding benefits. The Supreme Court disagreed, holding that the first OAH order was not a "prior adjudication" of workers' compensation benefits and provided no basis to implicate the principle of collateral estoppel. View "Lower v. Peabody Powder River Services, LLC" on Justia Law

In this case concerning a "race to permit" dispute between the parties in this case, both of whom held mineral interests in certain drilling and spacing units and both of whom wanted to be the "operator" of those units, the Supreme Court reversed the judgment of the district court granting Defendant's motion to dismiss for lack of subject matter jurisdiction, holding that the district court and not the Wyoming Oil and Gas Conservation Commission was the proper forum to resolve this case.Defendant won the race to permit and obtained operator status over the lands at issue. Plaintiff filed a complaint alleging that Defendant violated Wyo. Stat. Ann. 40-27-101, which prohibits a party from trespassing on private lands to unlawfully collect resource data. The district court granted Defendant's motion to dismiss, concluding that the Commission had primary jurisdiction to resolve the dispute and that Plaintiff failed to exhaust its administrative remedies. The Supreme Court reversed, holding (1) Plaintiff sufficiently pleaded standing under section 40-27-101 and the Declaratory Judgments Act; (2) the district court abused in dismissing the complaint for failure to exhaust administrative remedies because the Commission did not have jurisdiction to consider Plaintiff's civil trespass claim; and (3) the court abused its discretion in relying on the primary jurisdiction doctrine. View "Devon Energy Production, LP v. Grayson Mill Operating, LLC" on Justia Law

The Supreme Court reversed the decision of the district court reversing the decision of the State Board of Equalization affirming the ruling of the County Board of Equalization against the Town of Pine Bluffs in its appeal from the Laramie County Assessor's denial of a request for exemption from taxation for a daycare facility operated by the Town, holding that the County Board's order was in accordance with law, was not arbitrary, capricious or an abuse of discretion, and was supported by substantial evidence in the record.In 201y, the Town filed requests for exemption from the assessment of its daycare facility. The County Assessor denied the requests, and the County Board and State Board affirmed. The district court ruled in favor of the Town and reversed the decision of the State Board. The Supreme Court reversed and reinstated the order of the County Board, holding that the County Board's decision did not constitute reversible error. View "Eisele v. Town of Pine Bluffs" on Justia Law

The Supreme Court reversed the judgment of the Wyoming Oil and Gas Conservation Commission approving only one out of two applications filed by Exaro Energy III, LLC seeking the approval of adjacent drilling and spacing units (DSUs) in the Jonah Field, holding that the Commission's denial of Exaro's other application was arbitrary and capricious.At a contested case hearing the parties agreed that the evidence presented would apply to both applications. At the hearing's conclusion, the Commission found as to both applications that Exam had met its burden of proof and provided evidence satisfying the statutory requirements for the establishment of a DSU. However, the Commission approved one application and denied the other. The Supreme Court reversed in part, holding (1) substantial evidence supported the Commission's finding that Exaro's evidence satisfied the statutory requirements for establishment of a DSU in both applications; and (2) the Commission's decision to grant only one of the applications was arbitrary and capricious. View "Exaro Energy III, LLC v. Wyoming Oil & Gas Conservation Commission" on Justia Law

The Supreme Court affirmed the order of the district court affirming the decision of the Board of Coroner Standards refusing to investigate the Teton County Coroner's alleged misconduct during a coroner's inquest, holding that the Board does not have the authority to review a complaint that a coroner failed to comply with the Board's standards dealing with the investigation of coroner cases.In a related action, the Supreme Court affirmed the district court's dismissal of an action seeking to set aside the coroner's inquest verdict in In re Birkholz, 434 P.3d 1102 (Wyo. 2019). While that action was pending, Plaintiffs requested that the Board investigate the coroner's alleged misconduct. The Board refused to investigate the inquest, concluding that it did not have the statutory authority to do so. The district court affirmed the Board's refusal to investigate. The Supreme Court affirmed, holding that the legislature did not authorize the Board to investigate a coroner's conduct during an inquest. View "Hayse v. Wyoming Board of Coroner Standards" on Justia Law

In these appeals from the district court's order affirming in part and reversing and remanding in part the decision of the Wyoming Board of Medicine suspending Dr. Rebecca Painter's physician's license the Supreme Court dismissed the appeals for want of jurisdiction holding that the district court's order was not an appealable order under Wyo. R. App. P. 1.05.For violations of various provisions of the Medical Practice Act, Wyo. Stat. Ann. 33-26-101 through 703, the Board suspended Dr. Painter's physician's license for a minimum of five years, fined her $15,000, and ordered her to pay one-half of the costs of the proceedings. The district court affirmed in part and reversed in part, holding that there was insufficient evidence that Dr. Painter violated some of the provisions for which her license was suspended. The court also reversed and remanded the Board's decision assessing Dr. Painter one-half of the costs of the proceedings. Dr. Painter appealed, and the Board filed a cross-appeal. The Supreme Court dismissed the appeals, holding that the district court's order was not a final appealable order. View "McGill v. Painter" on Justia Law

The Supreme Court affirmed the decision of the Wyoming Board of Equalization affirming the determination of the Department of Revenue that Delcon Partners, LLC's purchase of a portion of Delcon, Inc's tangible and intangible assets was not exempt from sales tax, holding that the Department correctly concluded that the transaction was not excluded from the definition of "sale" under Wyo. Stat. Ann. 39-15-101(a)(vii)(N) and was subject to sales tax.Delcon Partners purchased twenty-eight percent of Delcon, Inc's assets. The Department determined that the transaction was not exempt from sales tax because Delcon Partners did not purchase at least eighty percent of the total value of the assets, including cash and accounts receivable. The Board affirmed. Delcon appealed, arguing that section 39-15-101(a)(vii)(N) should be interpreted to require only a purchase of eighty percent of a seller's tangible personal property rather than eighty percent of its total Wyoming assets. The Supreme Court affirmed, holding that the statute plainly conditions exclusion from the definition of "sale" on the purchase of at least eighty percent of the value of all of a business entity's assets located in Wyoming, which did not happen in this case. View "Delcon Partners LLC v. Wyoming Department of Revenue" 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 denial of Appellant's application to the Department of Workforce Services, Workers' Compensation Division for permanent partial disability (PPD) benefits, holding that the OAH's decision was not contrary to the overwhelming weight of the evidence.After Appellant injured his back the Division awarded him temporary benefits. When several years had passed without relief from his pain, Appellant appleid for PPD benefits. The Division denied Appellant's application. The OAH upheld the Division's denial of PPD benefits, concluding that Appellant failed to prove his work injury was the cause of his inability to return to employment and failed to prove that he timely filed his PPD application. The Supreme Court affirmed, holding (1) the OAH correctly calculated the limitations period under Wyo. Stat. Ann. 27-14-405(h)(ii); and (2) there was substantial evidence to support the OAH's conclusion that Appellant failed to prove that his injury was the cause of his inability to return to work. View "Camacho v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court reversed the order of the district court affirming the order of the Office of Administrative Hearings (OAH) upholding the Department of Workforce Services, Workers' Compensation Division's (Division) final determination regarding compensability, holding that the OAH erred in its determination that equitable estoppel did not bar the Division from asserting the statute of limitations as a defense.The OAH affirmed the final determination of the Division denying benefits to Appellant on the grounds that Appellant did not file a claim for benefits within the one-year statute of limitations set forth in Wyo. Stat. 27-14-503(a). The Supreme Court reversed, holding that the Division was estopped from asserting the statute of limitations as a defense, and therefore, the OAH's conclusion that section 27-14-503(a) barred Appellant's claim was not in accordance with law. View "Sweetalla v. State ex rev. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court affirmed the decision of the Office of Administrative Hearings (OAH) denying Appellant's request for permanent partial disability benefits, holding that the OAH's decision was supported by substantial evidence and was not arbitrary or capricious.In denying Appellant permanent partial disability benefits the hearing examiner determined that Appellant had not established that because of his injury he was unable to return to employment at a wage of at least ninety-five percent of his monthly earnings at the time of his injury. On appeal, Appellant claimed that the hearing examiner should have found dispositive the undisputed fact that Appellant had applied for over fifty positions and still had no job. The Supreme Court affirmed, holding that the hearing examiner's decision was not contrary to the overwhelming weight of the evidence, and the district court did not err in affirming the hearing examiner's conclusion. View "Bollinger v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law