Justia Injury Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court entered on the jury's verdict finding Defendant not negligent, holding that there was sufficient evidence to support the jury verdict.Following a car collision, Plaintiff sued Defendant for negligence. During trial, Plaintiff moved for judgment as a matter of law on the issue of Defendant's negligence. The district court reserved its ruling on the motion and gave the case to the jury. The jury found Defendant not negligent, and the court entered judgment on the verdict. The Supreme Court affirmed, holding (1) the court acted appropriately in sending the issue of Defendant's negligence to the jury; and (2) the jury could reasonably conclude from the evidence that Defendant failed to meet his burden to establish that Defendant breached his duty of ordinary care under the circumstances. View "Wageman v. Harrell" on Justia Law

The Supreme Court affirmed the judgment of the district court finding that Plaintiff's complaint against Defendant, a surgeon, alleging that he negligently treated Plaintiff's spinal condition, was barred by the statute of limitations, holding that the district court correctly found that Plaintiff's complaint was untimely filed.In her complaint, Plaintiff alleged that Defendant did not meet the applicable standard of care in his performances of surgeries on her and in her after care. Defendant moved for summary judgment, asserting that the complaint was barred by the applicable statute of limitations, Wyo. Stat. Ann. 1-3-107. The district court granted the motion. The Supreme Court affirmed, holding that the district court did not err in finding that the statute of limitations expired four days before Plaintiff's complaint was filed. View "Candelaria v. Karandikar" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiffs' complaint under Wyo. R. Civ. P. 12(b)(6) and (c), holding that the district court did not err.Plaintiffs sued Defendants asserting claims for defamation per se, tortious interference with a prospective economic advantage and business expectancy, and false light invasion of privacy. The district court dismissed all claims. The Supreme Court affirmed, holding (1) Plaintiffs did not state claims for defamation per se; (2) Plaintiffs could not recast their second cause of action as a claim for prima facie tort; and (3) Plaintiffs did not state a claim for false light invasion of privacy. View "Bextel v. Fork Road LLC" on Justia Law

The Supreme Court remanded this case to the district court with instructions to determine whether excusable neglect extended Plaintiff's time to file the petition for review of the decision of the Office of Administrative Hearings (OAH) concluding that Plaintiff's infection was not compensable, holding that the record did not reveal whether the district court considered the question of excusable neglect.Plaintiff scraped his knuckle on a locker as he was getting ready to leave a trona mine, where he worked. The scrape developed necrotizing fasciitis, causing serious injuries. The Department of Workforce Services, Workers' Compensation Division, deemed Plaintiff's injury compensable. The OAH served an order concluding that Plaintiff's injuries were not compensable. The district court reversed, concluding that Plaintiff's infection was compensable. Plaintiff's employer appealed, arguing that the district court lacked jurisdiction because the petition for judicial review was untimely filed. The Supreme Court remanded the case for the limited purpose of determining whether excusable neglect extended the time for filing a petition for review. View "Tata Chemicals Soda Ash Partners, Ltd v. Vinson" on Justia Law

The Supreme Court affirmed the decision of the district court granting Goshen County Fairgrounds summary judgment on its assertion of governmental immunity and dismissing Plaintiff's negligence action, holding that Plaintiff did not establish a genuine issue of material fact that would preclude summary judgment on the basis of the Fairgrounds' immunity.Plaintiff fell at an event held in one of the Goshen County Fairgrounds' buildings. Plaintiff filed a complaint against Goshen county, the State, and the Fairgrounds, alleging negligence. The district court granted summary judgment for the Fairgrounds. The Supreme Court affirmed, holding that disputed issues of material fact did not exist so as to preclude summary judgment on the question of whether the Fairgrounds and its employees were negligent in the operation or maintenance of the building. View "Varela v. Goshen County Fairgrounds" on Justia Law

The Supreme Court affirmed the judgment of the district court finding in favor of Defendant, an anesthesiologist, on Plaintiff's medical negligence claim, holding that the district court did not abuse its discretion when it denied further investigation into a juror's communication with the court bailiff and that the erroneous admission of testimony regarding Defendant's character for truthfulness was harmless.Plaintiff brought this lawsuit claiming that Defendant negligently performed a regional block procedure in preparation for surgery to repair Plaintiff's broken wrist. After a trial, the jury unanimously found Defendant was not negligent. On appeal, Plaintiff argued that the district court erred when it refused to reopen voir dire after a juror spoke with the bailiff and abused its discretion when it allowed a defense witness to testify to Defendant's character for truthfulness. The Supreme Court affirmed, holding (1) Plaintiff's waived her challenge to the participation of the juror at issue, and even if she hadn't, the district court did not abuse its discretion in its treatment of the juror's communication with the bailiff; and (2) the district court abused its discretion in admitting testimony vouching for Defendant's honest character, but this error did not prejudice Plaintiff. View "Lubing v. Tomlinson" on Justia Law

The Supreme Court affirmed the judgment of the district court against Plaintiff on her negligent credentialing claim against the Board of Trustees of the Memorial Hospital of Carbon County (the Hospital), holding that the default judgment against Eric Dash, M.D. did not estop the Hospital from contesting his negligence.Plaintiff filed a complaint alleging negligence against Dr. Dash and negligent credentialing and vicarious liability against the Hospital. When Dr. Dash failed to answer or otherwise defend the district court entered a default judgment against him. A two-phase jury trial was subsequently on the negligent credentialing claim against the Hospital, with the first phase trying the question of Dr. Dash's negligence. The jury returned a verdict finding no negligence. The district court then entered judgment in favor of the Hospital, finding that the negligence of Dr. Dash was a prerequisite to liability against the Hospital for negligent credentialing. The Supreme Court affirmed, holding that the district court (1) did not err when it found the default judgment against Dr. Dash was not binding on the Hospital on the basis of collateral estoppel or issue preclusion; and (2) did not abuse its discretion when it bifurcated the issue of Dr. Dash's negligence from the negligent credentialing claim against the Hospital. View "Loeffel v. Dash" on Justia Law

In this personal injury action brought pursuant to the Workers' Compensation Act the Supreme Court affirmed in part and reversed in part the order of the district court granting summary judgment in favor of one of Plaintiff's co-employee supervisors, holding that genuine issues of material fact existed.Plaintiff was injured when his hand and arm became entangled in a pipe-straightening machine at his place of employment. Plaintiff sued his co-employee supervisors - Elvin Brown, Bill Wartenbee, and Bryce Mitchell - claiming they were not entitled to immunity from liability under the Act because they intentionally acted to cause physical harm or injury to Plaintiff. The district court granted summary judgment for Defendants. The Supreme Court reversed in part, holding (1) Brown and Wartenbee were entitled to judgment as a matter of law and were immune from liability for Plaintiff's injury; and (2) Plaintiff established genuine issues of material fact against Mitchell precluding summary judgment. The Court remanded the claim against Mitchell for trial. View "Ramirez v. Brown" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Plaintiffs' lawsuit against the Wyoming State Hospital and its staff for medical malpractice, negligence, and wrongful death, holding that Plaintiffs' allegations were sufficient to survive a motion to dismiss and that the Hospital and Dr. Sarah Rogers were not immune from suit.Robert Anderson died while in the custody of the Hospital. Prior to his death, Anderson had been adopted by his paternal grandmother, who had since died. Robert Craft, Anderson's biological father and his adoptive brother, and Sabrina Craft, Anderson's appointed personal representative and Robert's wife, brought this action. The district court dismissed the complaint, holding (1) the Crafts lacked standing and had failed to state a claim under Wyo. R. Civ. P. 12(b)(6); (2) the Crafts were not qualified death beneficiaries because of Anderson's adoption; and (3) Dr. Rogers and the Hospital were immune from suit under the Wyoming Governmental Claims Act (WGCA). The Supreme Court reversed, holding (1) as Anderson's adoptive brother, Craft was a qualified wrongful death beneficiary; (2) Plaintiffs' allegations of medical malpractice, negligence, and medical malpractice were sufficient to survive a motion to dismiss; and (3) Dr. Rogers and the Hospital were not immune from suit. View "Craft v. State ex rel. Wyo. Department of Health" on Justia Law

The Supreme Court affirmed the decision of the Medical Commission upholding that decision of the Wyoming Workers' Safety and Compensation Division denying workers' compensation benefits because Appellant failed to establish a causal connection between his injury and employment, holding that the Commission's decision was not contrary to the overwhelming weight of the evidence.The Division denied benefits because Appellant did not submit evidence establishing a causal connection between his injury and employment as required by Wyo. Stat. Ann. 27-14-603(a). The Commission upheld the denial of benefits after rejecting the opinions of Appellant's medical experts. The Supreme Court affirmed, holding that the Commission's determination that Appellant failed to meet his burden under section 27-14-603(a) for an injury occurring over a substantial period of time was not contrary to the overwhelming weight of the evidence. View "McMillan v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law