Justia Government & Administrative Law Opinion Summaries

Wyo. Stat. Ann. 27-14-605 does not bar a claimant from receiving temporary total disability benefits for a second compensable injury when he has not filed a claim for benefits on his original injury within four years.Six years after receiving workers’ compensation benefits for a workplace injury to his right knee, James Hall underwent another knee surgery that was approved by the Workers’ Compensation Division. The Division denied Hall’s application for temporary total disability (TTD) benefits, concluding that, under section 27-14-605(b), Hall was not entitled to TTD benefits related to the surgery after not seeking benefits on his original injury for over four years. The Office of Administrative Hearings (OAH), however, concluded that section 27-14-605 did not govern Hall’s claim because Hall suffered a second compensable injury that section 27-14-605 did not control and that Hall was entitled to TTD benefits as a matter of law. The district court affirmed. The Supreme Court affirmed, holding that Hall suffered a second compensable injury and was therefore entitled to TTD benefits pursuant to Wyo. Stat. Ann. 27-14-404(a). View "In re Worker's Compensation Claim of James A. Hall" on Justia Law

The Supreme Court affirmed the district court’s grant of summary judgment in favor of Plaintiff in this declaratory judgment action against the Board of County Commissioners of Teton County challenging the Teton County Land Development Regulation prohibiting fractional ownership of campgrounds, holding that the regulation was unenforceable because it exceeded the County’s zoning authority. Specifically, the Court agreed with Plaintiff that the regulation prohibiting fractional ownership did not regulate the use of the land, only its ownership, and was, therefore, beyond the County’s zoning authority and unenforceable. View "Board of County Commissioners of Teton County, Wyoming v. Mackay Investments, LLC" on Justia Law

The Supreme Court affirmed the decision of the district court affirming the decision in favor of Petitioner’s former attorneys (Respondent-law firm) by a panel of the Wyoming State Bar Committee for Resolution of Fee Disputes. The Court held (1) the panel’s conclusion that it was neither unreasonable nor abusive for Respondent to bill its time using minimum increments of fifteen minutes was supported by substantial evidence; and (2) substantial evidence supported the panel’s conclusion that Respondent exercised billing judgment and did not excessively bill Petitioner for substantive and necessary communication between firm members and employees about Petitioner's case. View "Manigault v. Daly & Sorenson, LLC" on Justia Law

The Supreme Court affirmed the decision of the district court ruling that the Office of Administrative Hearings (OAH) erred in upholding the Wyoming Workers’ Compensation Division’s denial of benefits to Richard Williams.Williams suffered a head injury while working as a well operator. Williams argued that a flash fire started him and caused him to fall backward and strike his head. The Division denied benefits, determining that Williams’ injury did not arise out of an in the course of his employment. The OAH upheld the denial of benefits, finding that Williams and his version of events lacked credibility. The district court reversed, concluding that the OAH decision was contrary to overwhelming medical evidence that Williams injured his head while engaged in work-related activities. The Supreme Court affirmed, holding that Williams offered evidence sufficient to raise a presumption that he suffered a head injury that arose out of his employment and that the Division failed to rebut that presumption. View "State ex rel. Department of Workforce Services, Workers' Compensation Division v. Williams" on Justia Law

The Supreme Court affirmed the decision of the district court ruling that the Office of Administrative Hearings (OAH) erred in upholding the Wyoming Workers’ Compensation Division’s denial of benefits to Richard Williams.Williams suffered a head injury while working as a well operator. Williams argued that a flash fire started him and caused him to fall backward and strike his head. The Division denied benefits, determining that Williams’ injury did not arise out of an in the course of his employment. The OAH upheld the denial of benefits, finding that Williams and his version of events lacked credibility. The district court reversed, concluding that the OAH decision was contrary to overwhelming medical evidence that Williams injured his head while engaged in work-related activities. The Supreme Court affirmed, holding that Williams offered evidence sufficient to raise a presumption that he suffered a head injury that arose out of his employment and that the Division failed to rebut that presumption. View "State ex rel. Department of Workforce Services, Workers' Compensation Division v. Williams" on Justia Law

At issue was whether this case presented a justiciable issue when the Supreme Court could not render a decision binding on a federal agency and could only offer an advisory opinion that may or may not ultimately bind the parties.Berenergy Corporation, which produced oil from several sites under oil and gas leases granted by the United States Department of the Interior, Bureau of Land Management (BLM), sought a declaratory judgment that the terms of its BLM oil leases provided it with rights superior to any obtained by Peabody Energy Corporation through its coal leases. The district court granted in part and denied in part both parties’ motions for summary judgment. Both parties appealed. The Supreme Court remanded the case for further proceedings before the district court, holding (1) Congress intended that the issues raised by Berenergy be decided by the Secretary of the Interior or its BLM designees; (2) there was no express consent by the federal government for the Secretary or the BLM to be made a party to suits such as this for the purpose of informing a congressionally approved decision by the district court; but (3) the court nonetheless remands this case for an evaluation of whether a federal agency may participate in this suit. View "Berenergy Corp. v. BTU Western Resources, Inc." on Justia Law

The Supreme Court affirmed the district court’s decision affirming the decision of the Medical Commission, which sustained the Wyoming Workers’ Compensation Division’s termination of Sarah Morris’s temporary total disability (TTD) benefits. The Division terminated the TTD benefits after determining that Morris had reached maximum medical improvement. The Supreme Court held (1) the Commission appropriately determined that Morris had reached MMI and terminated her TTD benefits; and (2) substantial evidence existed to support the Commission’s decision that Morris’s injury to her right knee was not work-related. View "Morris v. State ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court affirmed the district court’s dismissal of a complaint brought by the Town of Pine Bluffs alleging that Laramie County illegally taxed a day care center that the Town owned and operated. The Town sought an injunction under Wyo. Stat. Ann. 39-13-109(c)(i), alleging that the property was used for a governmental purpose and was therefore exempt under Wyo. Stat. Ann. 39-11-105(a)(v). The district court granted the County’s motion to dismiss, concluding that the Town should have exhausted administrative remedies before resorting to an injunction. The Supreme Court affirmed, holding that section 39-13-109(c)(i) did not provide the Town a remedy for an error in assessing the day care center and that it needed to resort to the administrative process instead. View "Town of Pine Bluffs v. Eisele" on Justia Law

The Supreme Court affirmed the decision of the Teton County Board of County Commissioners granting Four Shadows, LLC a basic use permit (BUP) to use its property in Teton Village for temporary construction storage/staging. The court held (1) Appellants had an interest that was greater than the general public’s, giving them standing to maintain their appeal as persons aggrieved and adversely affected in fact by the Board’s decision to issue the permit; and (2) the Board’s decision to grant Four Shadows a BUP for temporary use of the property for construction storage/staging was not arbitrary, capricious, an abuse of discretion, or otherwise contrary to law. View "Tayback v. Teton County Board of County Commissioners" on Justia Law

The Supreme Court affirmed the Medical Commission’s denial of Dennis Howe’s claim for permanent partial impairment (PPI) benefits for a work-related injury Howe suffered. The district court affirmed the decision of the Commission. In affirming the district court, the Supreme Court held (1) the Commission’s determination that Howe did not prove he was entitled to an increased impairment rating due to the result of chlorine exposure was supported by substantial evidence, and the Commission could have reasonably concluded as it did; and (2) the Commission’s decision was not arbitrary and capricious. View "Howe v. State, ex rel., Department of Workforce Services" on Justia Law