The Supreme Court affirmed in part and reversed in part the district court’s dismissal of Plaintiff’s complaint alleging negligence and violations of 42 U.S.C. 1983 after Linda Gelok was injured after being left unattended for twenty-five hours at the Wyoming State Hospital (WSH), holding that the complaint alleged sufficient facts to state a claim for relief under 42 U.S. C. 1983 against Paul Mullenax, WSH Administrator, in his individual capacity. On behalf of Linda Gelok, an involuntarily committed incompetent person, Plaintiff sued the WSH, the Wyoming Department of Health, and Mullenax, WSH Administrator, in his official and individual capacities, alleging negligence and violation of her constitutional rights under 42 U.S.C. 1983. The district court dismissed the negligence action as time-barred. As to the constitutional claims, the district court found that the WSH, the Department, and Mullenax in his official capacity were entitled to Eleventh Amendment immunity and that Mullenax was entitled to qualified immunity in his individual capacity. The Supreme Court held (1) Wyo. Stat. Ann. 1-3-107 barred Plaintiff’s negligent health care claim; (2) the district court properly dismissed Plaintiff’s 42 U.S.C. 1983 claims against most defendants; but (3) Plaintiff’s complaint alleged sufficient facts to state a claim for relief under 42 U.S.C. 1983 against Mullenax in his individual capacity. View "Wyoming Guardianship Corp. v. Wyoming State Hospital" on Justia Law
In 2010, the director of the Wyoming Guardianship Corporation filed a petition for emergency appointment of a temporary guardian for Robert Sands, who was then seventy years old and suffered from dementia and other medical problems. The district court held a guardianship was necessary and appointed Richard Brown as guardian. Sands sought to terminate the guardianship, and the district court denied the petition. Six months later, however, the district court held a review hearing and terminated the guardianship, finding there was no longer a need for the guardianship. Prior to the hearing, Sands filed a complaint against Brown, alleging that Brown had breached his duties. The district court ruled in favor of Brown on Sands' complaint, concluding that Brown substantially complied with the statutes and did not violate his fiduciary duties, and awarded Brown and his attorney fees and costs. The Supreme Court affirmed, holding that the district court did not err in when it denied Sands' petition to terminate the guardianship, reopened the guardianship for the purpose of awarding fees and costs, and dismissed Sands' complaint against Brown. View "Sands v. Brown" on Justia Law
After RB, a middle-aged man, was emergently detained as a suicide risk at West Park Hospital, the district court involuntarily hospitalized RB at the Wyoming State Hospital, where he was detoxified of opiates and other controlled substances and eventually stabilized on psychotropic medications. The State Hospital then notified the district court and the county attorney that it intended to discharge RB. The county attorney filed an objection with the district court, claiming a right to a hearing on the merits of the State Hospital's decision. The district court concluded that the county had no standing to object to RB's discharge. The Supreme Court affirmed, holding that the involuntary hospitalization statutes do not provide authority for a county attorney to object to the proposed discharge of a patient from involuntary civil commitment. View "State v. Wyo. State Hosp." on Justia Law
Employee slipped and fell while taking out garbage for Employer. Employee was diagnosed with injuries to her right hip, shoulder, and elbow and received workers' compensation benefits for her shoulder injury and an umbilical hernia. After Employee experienced continuing shoulder pain, an MRI and x-rays of Employee's cervical spine were ordered. The Wyoming Worker's Safety and Compensation Division denied Employee reimbursement of the payments for those medical expenses on the grounds that injuries to the cervical spine were not the result of a work-related injury. The Office of Administrative Hearings upheld the Division's decision, and the district court affirmed. The Supreme Court affirmed, holding that it was reasonable for the hearing examiner to conclude, based upon substantial evidence in the record, Employee had not met her burden of establishing that, although the condition of her cervical spine may have been causing shoulder pain, any damage to the cervical spine was not a result of her slip and fall.
Defendant William Bruyette was charged with felony possession of marijuana. At trial, he sought to introduce evidence that he obtained the marijuana in California with a prescription for medical marijuana. The district court granted the State's in limine motion to exclude evidence relating to a medical marijuana defense and instructed the jury that possession of medical marijuana was not a defense to the crime charged. The jury convicted defendant of felony possession of marijuana. Defendant appealed, claiming the district court denied him his constitutional right to present his defense. The Supreme Court affirmed, holding that the question of whether or not defendant had a medical marijuana card from a California physician was irrelevant because it is illegal, under Wyoming law, for a physician to prescribe or order the possession of marijuana.