Justia Injury Law Opinion Summaries

Charles Leonhardt, a pretrial detainee at the Big Horn County Jail, suffered from back pain and was eventually diagnosed with two lower back infections after being transported to a hospital. He sued Big Horn County Sheriff Ken Blackburn, Jail Captain Debbie Cook, unnamed detention officers, the Big Horn County Sheriff’s Office, and the Jail, alleging negligence and deliberate indifference under the Fourteenth Amendment.The District Court of Big Horn County granted summary judgment to the defendants on both claims. The court found that Sheriff Blackburn had fulfilled his duty to arrange for medical care by contracting with Midway Medical Clinic, which provided medical services to inmates. The court also determined that the actions of Sheriff Blackburn, Captain Cook, and the detention officers were reasonable and did not proximately cause Mr. Leonhardt’s injuries. Additionally, the court found no evidence of deliberate indifference to Mr. Leonhardt’s medical needs, as the defendants ensured he received timely medical care.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decision. The court held that there was no genuine dispute of material fact regarding the negligence claim, as the defendants acted reasonably and provided Mr. Leonhardt with access to medical care. The court also found no evidence that the defendants were aware of and disregarded an excessive risk to Mr. Leonhardt’s health, thus failing to meet the subjective component of a deliberate indifference claim. Consequently, the court affirmed the summary judgment in favor of the defendants on both the negligence and Fourteenth Amendment deliberate indifference claims. View "Leonhardt v. Big Horn County Sheriff's Office" on Justia Law

Marco Cardenas filed a negligence lawsuit against Rajean Fossen following a motor vehicle accident near Hudson, Wyoming. During the trial, Cardenas moved for judgment as a matter of law on Fossen’s liability, which the district court denied, allowing the jury to decide. The jury found Fossen was not negligent. Cardenas then renewed his motion for judgment as a matter of law and filed a motion for a new trial, both of which the district court denied. Cardenas appealed, arguing the district court should have granted his motion for judgment as a matter of law and remanded the case for a new trial on causation and damages.The district court of Fremont County initially granted Cardenas’s motion for summary judgment on Fossen’s affirmative defense of comparative fault but denied summary judgment on Fossen’s liability, citing a genuine issue of material fact. After a four-day jury trial, the jury found Fossen was not negligent. Cardenas’s post-trial motions for judgment as a matter of law and for a new trial were denied by the district court.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court held that Fossen’s statements during the trial did not constitute an unqualified admission of liability. The evidence presented allowed for more than one reasonable inference, and the jury could reasonably conclude that Fossen was not negligent. The court also found that the district court did not abuse its discretion in denying Cardenas’s motion for a new trial, as there was sufficient evidence to support the jury’s verdict. The Supreme Court affirmed the district court’s rulings, upholding the jury’s finding that Fossen was not negligent. View "Cardenas v. Fossen" on Justia Law

Darren J. Gray suffered a heart attack while working on a road construction project and applied for workers' compensation benefits. The Wyoming Workers’ Safety and Compensation Division denied his request. After a contested case hearing, the Office of Administrative Hearings also denied the request, and the district court affirmed that decision. Mr. Gray appealed, arguing that his work exertion was unusual or abnormal under Wyoming law.The Office of Administrative Hearings found that Mr. Gray did not meet his burden of proof under Wyo. Stat. Ann. § 27-14-603(b)(ii) to show that his work exertion was unusual or abnormal for his employment. The Hearing Examiner determined that the tasks Mr. Gray performed on the day of his heart attack, including lifting and slamming metal pipes, were consistent with the job duties of similarly-situated employees. The district court affirmed this decision, agreeing that Mr. Gray's exertion was not clearly unusual or abnormal for his type of employment.The Wyoming Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the Hearing Examiner's conclusion was supported by substantial evidence, including job descriptions and testimony from Mr. Gray's supervisor. The court found that the tasks Mr. Gray performed were within the normal scope of his employment duties. The court also noted that the independent medical examiner's testimony did not establish that the exertion was unusual. Therefore, the court concluded that Mr. Gray did not meet the statutory requirements for workers' compensation benefits for his heart attack. View "Gray v. State, Ex Rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

Anne G. McNair experienced a perforated esophagus and infection following cervical fusion surgery performed by Dr. Joshua D. Beck at North Lincoln County Hospital District, d/b/a Star Valley Health. Dr. Beck, employed by Orthopaedics of Jackson Hole, P.C., d/b/a Teton Orthopaedics, continued to treat her post-surgery. McNair filed a complaint against Dr. Beck, Teton, and Star Valley, alleging medical malpractice, negligence, and vicarious liability. The district court dismissed her complaint, citing the statute of limitations, and denied her motion to amend the complaint, deeming it futile.The District Court of Lincoln County granted the defendants' motions to dismiss, concluding that McNair's claims were filed beyond the two-year statute of limitations for medical malpractice actions. The court determined that the continuous treatment rule did not apply, as McNair's injury stemmed from a single act of negligence during the surgery on December 30, 2020. Consequently, the court found that the statute of limitations began on December 31, 2020, the date McNair was discharged from the hospital, making her April 2023 filings untimely. The court also denied McNair's motion to amend her complaint, asserting that any amendment would be futile.The Supreme Court of Wyoming reviewed the case and found that the district court erred in its application of the continuous treatment rule. The Supreme Court held that the continuous treatment rule applies when a medical provider has provided ongoing care for the same or related complaints. The court noted that McNair's complaint alleged continuous treatment by Dr. Beck and Teton into early 2021, which could extend the statute of limitations. The court also found that the district court abused its discretion in denying McNair's motion to amend her complaint, as the proposed amendments did not show on their face that the claims were untimely. The Supreme Court reversed the district court's decision and remanded the case for further proceedings. View "McNair v. Beck" on Justia Law

Ming Zheng, a drilling field engineer, suffered a work-related injury to her right ankle while attempting to disassemble a tool string. She reported the injury and received workers' compensation benefits. Approximately a year later, Zheng sought additional benefits for an injury to her left ankle and requested preauthorization for surgery on her right ankle. The Wyoming Department of Workforce Services, Workers' Compensation Division, denied these requests, finding the treatments were not related to her original work injury. The Division also discontinued her temporary total disability benefits after she received a 0% impairment rating.The Wyoming Medical Commission upheld the Division's denial of benefits and discontinuation of temporary total disability benefits after a contested case hearing. The Commission found that Zheng failed to prove the requested treatments for her left ankle were related to her compensable work injury and that the surgery on her right ankle was necessary. The district court affirmed the Medical Commission's decision.The Wyoming Supreme Court reviewed the case and affirmed the lower court's decision. The Court held that substantial evidence supported the Medical Commission's findings that Zheng's left ankle issues were not related to her work injury and that the requested surgery on her right ankle was not necessary. The Court also found that the Medical Commission did not act arbitrarily or capriciously in admitting an addendum to Dr. Orth's independent medical evaluation, as Zheng had the opportunity to cross-examine Dr. Orth and present rebuttal evidence. The Court concluded that the Medical Commission's decision was supported by substantial evidence and was not arbitrary or capricious. View "Zheng v. State of Wyoming, Ex Rel. Department of Workforce Services" on Justia Law

James Corley, as the representative of his deceased son's beneficiaries, filed a wrongful death lawsuit against Wyoming Rents, LLC. His son had died in a work-related accident while operating a manlift rented from Wyoming Rents. Corley's counsel missed several deadlines to file an amended complaint, continued to pursue claims against another party that the district court had dismissed, and attempted to engage in discovery without a properly filed amended complaint. Consequently, the district court granted Wyoming Rents' motion to dismiss the action with prejudice. Corley appealed, arguing that a lesser sanction was more appropriate.The district court had previously dismissed Wyoming Machinery Company (WMC) from the case due to lack of claims against it and granted Corley leave to file a second amended complaint. However, Corley failed to meet the deadline for filing the revised complaint and included WMC in the complaint's caption despite the court's dismissal. The court granted Corley another chance to file an amended complaint, but he again missed the deadline. Wyoming Rents then filed a motion to dismiss the case based on Corley's failure to file any pleading by the court's deadline.The Supreme Court of Wyoming found no abuse of discretion in the district court's decision to dismiss the case with prejudice. The court noted that Corley's counsel demonstrated a complete lack of diligence throughout the case, which prejudiced Wyoming Rents by forcing it to incur substantial attorney’s fees and hindered the court's ability to move forward in resolving the case. The court affirmed the district court's decision to dismiss the case with prejudice. View "Corley v. Wyoming Rents, LLC" on Justia Law

The case involves a legal malpractice claim brought by Patricia Kappes against Diana Rhodes and Rhodes Law Firm, LLC. Kappes alleges that Rhodes' negligence resulted in the loss of a legal action against a defendant. The legal action in question pertains to the wrongful death of Kappes' mother, Lula M. Tanner, who was a resident at Deseret Health and Rehab at Rock Springs, LLC. Kappes had sought legal recourse for her mother's death against her mother's healthcare providers. However, Rhodes failed to timely file an application with the Wyoming Medical Review Panel and a wrongful death complaint against Ms. Tanner’s healthcare providers, which Kappes alleges constitutes legal malpractice.The District Court of Laramie County, Wyoming, certified four questions to the Supreme Court of Wyoming. These questions pertained to the role of the collectibility of the judgment in the underlying action in legal malpractice cases in Wyoming. The lower court sought to understand whether the collectibility of a judgment is a relevant consideration in a legal malpractice case, which party bears the burden of proving the underlying judgment would have been collectible, whether collectibility must be pled as an affirmative defense, and whether the Collectibility Doctrine is available as a defense to an attorney who has admitted liability.The Supreme Court of Wyoming concluded that the collectibility of the judgment is an essential part of the causation/damages element of a legal malpractice action. The client, in this case, Kappes, has the burden to prove by a preponderance of the evidence that any judgment she would have obtained in the underlying action would have been collectible. The court held that the client's burden includes showing she would have obtained a judgment in the underlying action and the judgment would have been collectible. The court did not find it necessary to answer the third and fourth certified questions as they were predicated on the court deciding collectibility is an affirmative defense to be pled and proved by the attorney. View "Kappes v. Rhodes" on Justia Law

An automobile accident in Idaho resulted in Emily Fairbanks receiving severe injuries while a passenger in a vehicle driven by Holly Galbraith. Fairbanks filed two lawsuits: one against the Idaho Transportation Department claiming negligent maintenance of a guardrail, and another against Galbraith in Wyoming for negligence. Galbraith sought to dismiss the Wyoming suit, citing that the statute of limitations had elapsed. The district court denied the motion. Later, Galbraith was granted summary judgment based on collateral estoppel, preventing relitigation of negligence and damages issues established in the Idaho case.Both parties appealed. Galbraith claimed the lower court had erred in its conclusion about the statute of limitations, while Fairbanks disputed the application of collateral estoppel and the application of Idaho's statutory cap on non-economic damages. The Supreme Court of Wyoming concluded that the statute of limitations had run before Fairbanks filed her complaint, reversing the district court's ruling on the issue. The court did not address the merits of the collateral estoppel appeal. The court found that under Idaho law, Fairbanks' lawsuit was time-barred as she made no effort to locate Galbraith during the time Galbraith was out of state, thus the statute of limitations was not tolled. View "Galbraith v. Fairbanks" on Justia Law

In a car accident resulting in the death of a motorcyclist, the driver, Yvonne Patrice Kessel, was convicted of one count of aggravated vehicular homicide. The State of Wyoming Supreme Court affirmed the conviction, holding that Kessel’s proposed jury instruction, which suggested that the jury could consider the victim’s actions when determining proximate cause, was not a proper theory of defense. The Court found that Kessel was essentially arguing that the State failed to prove the proximate cause element of the charged offense, which it deemed a "claim of innocence" or "failure of proof" defense not warranting a special theory of defense instruction. The Court also ruled that the jury had been adequately instructed on the concept of proximate cause and that the instructions allowed both parties to argue their respective theories of the case. Thus, the Court concluded that the lower court did not abuse its discretion by denying Kessel’s proposed instruction. View "Kessel v. The State of Wyoming" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of the State in this action brought by Plaintiffs claiming that a contract health care provider for the State at the Wyoming Medium Correctional Institution (prison) acted negligently when she injected Appellants with the Janssen COVID-19 vaccine, holding that the State was immune from suit and liability.Plaintiffs, inmates at the prison, brought this action claiming that they were wrongfully injected with the Janssen COVID-19 vaccine because the consent forms Plaintiffs signed mentioned only the Moderna and Pfizer COVID-19 vaccines. The district court declined to allow Appellants additional time for limited discovery and granted summary judgment in favor of the State, finding that State had immunity. The Supreme Court affirmed, holding (1) the district court did not err when it declined to allow Plaintiffs limited discovery; and (2) the federal Public Readiness and Emergency Preparedness Act shielded the State from suit and liability in this case. View "Bird v. State" on Justia Law