Friday, May 29, 2009

New Resource on Supreme Court Nominee Sonia Sotomayor

We just received the following information:

New Resource on Supreme Court Nominee Sonia Sotomayor

The Law Library of Congress has launched a new resource on Supreme Court Nominee Sonia Sotomayor http://www.loc.gov/law/find/sotomayor.php. The site contains information on articles and books by Sotomayor, Congressional documents, cases, and web resources.

Wednesday, May 20, 2009

Summary 2009 WY 66

Summary of Decision issued May 20, 2009

Summaries are prepared by Law Librarians and are not official statements of the Wyoming Supreme Court.

Case Name: Straube v. State, ex rel. Wyoming Workers’ Safety and Comp. Div.

Citation: 2009 WY 66

Docket Number: S-08-0106

Appeal from the District Court of Campbell County, the Honorable Michael N. Deegan, Judge.

Representing Appellant Straube: Kenneth DeCock of Plains Law Offices LLP, Gillette, Wyoming.

Representing Appellee State: Bruce A. Salzburg, Wyoming Attorney General; John W. Renneisen, Deputy Attorney General; James Michael Causey, Senior Assistant Attorney General; Kristi M. Radosevich, Senior Assistant Attorney General.

Facts/Discussion: Straube suffered an injury to his right knee while at work. The Workers’ Compensation Division (Division) found the injury to be compensable and awarded benefits. Straube’s knee never healed and approximately one year later he sought pre-authorization from the Division for osteochondrial autograph implant surgery. The Division determined that Straube’s current knee problems solely related to a preexisting condition and denied further benefits.
It was undisputed that Straube suffered from a preexisting condition and that he suffered a compensable material aggravation of that condition. The first surgery was covered as being directly necessitated by the work injury. The Medical Commission relied on the reports from Dr. Davis and Dr. Whipp. Their opinions were not based so much on medical information as their individual thoughts on the state of the law. Dr. Davis stated he thought about the situation and since the initial injury could have occurred at anytime, the consequences of the surgery should not be the responsibility of the Division. But, the injury happened while Straube was on the job and the employer takes an employee as he finds him. Dr. Whipp and the Medical Commission discussed apportionment. The Commission’s ultimate conclusion was that since apportionment under the circumstances was not legally allowed, then no benefits should be granted. The inability to apportion the medical consequences of a work injury between the immediate injury and a preexisting condition is not a reason to deny benefits.

Conclusion: Benefits are awarded if the medical consequences are causally related to the work injury. The evidence in the case supports such causal connection. Straube’s knee never fully recovered after the work injury, as evidenced by the continued weakness in the knee and Straube’s continued pain. More importantly, the only medical evidence directly on point stated the currently recommended surgery would not be necessary had it not been for the work injury. The Court concluded the decision of the Medical Commission was against the overwhelming weight of the evidence.

Reversed.

J. Golden delivered the decision.

J. Burke dissenting, joined by C.J. Voigt: The Justices noted the majority seemed to discount the opinions of two of the reviewing physicians because they viewed the medical records but did not examine the patient which is a common procedure in compensation cases and does not render the evidence inadmissible or incompetent. It may affect the credibility or persuasiveness of the doctors’ opinions but it is up to the Medical Commission to determine the credibility of witnesses and the weight afforded to conflicting evidence.

Link: http://tinyurl.com/oxbb46 .

[SPECIAL NOTE: This opinion uses the "Universal Citation." It was given an "official" citation when it was issued. You should use this citation whenever you cite the opinion, with a P.3d parallel citation. Please note when you look at the opinion that all of the paragraphs are numbered. When you pinpoint cite to a quote, you should cite to this paragraph number rather than to any page number. If you need assistance in putting together a citation using the Universal Citation form, please contact the Wyoming State Law Library.]

Tuesday, May 19, 2009

Summary 2009 WY 65

Summary of Decision issued May 19, 2009

Summaries are prepared by Law Librarians and are not official statements of the Wyoming Supreme Court.

Case Name: Lieberman v. Mossbrook; Mossbrook v. Lieberman

Citation: 2009 WY 65

Docket Number: S-08-0159; S-08-0160

Appeal from the District Court of Fremont County, the Honorable Norman E. Young, Judge.

Representing Lieberman: William D. Bagley of Frontier Law Center, Cheyenne, Wyoming.

Representing Mossbrook, et al: Alexander K. Davison and Terry W. Connolly of Patton & Davison, Cheyenne, Wyoming.

Facts/Discussion: After Lieberman withdrew as a member of Wyoming.com LLC, Wyoming.com filed a petition for a declaratory judgment seeking a determination of its rights and Lieberman filed a complaint for dissolution of the company and the return of his share of its value. Three district court determinations and three appeals to the Court followed during which it was established that Lieberman’s withdrawal did not result in dissolution of the company, he was entitled to the return of his $20,000 capital contribution and he retained an equity interest in the company. Those determinations having been made, the declaratory action was dismissed. Lieberman then filed a complaint against the owners of Wyoming.com, who in the meantime had merged the limited liability company into a corporation. The district court granted partial summary judgment for Lieberman on his claim for conversion and set trial for determination of the value of his equity interest and his entitlement to other damages. The district court entered judgment on the conversion claim for Lieberman in the amount of $958,475.44. The district court found for the Mossbrooks on the remaining claims.
See the opinion for a complete summary of Lieberman I, II and III.

Statute of limitations: In a claim of conversion, the cause of action accrues when the plaintiff knew or should have known that his property was wrongfully converted. The dispute began in 1998 when Lieberman withdrew from Wyoming.com and demanded return of his proportionate share of the company’s value. He filed a complaint in June, 1998 well within the four year statute of limitations for conversion claims. The nature of Lieberman’s equity interest became clear in 2004 when the Court decided Lieberman II and within six months, he filed his claim for conversion. The district court correctly determined that Lieberman’s claim was not barred.
The law of the case: The Court’s decisions in the prior Lieberman cases were based upon an incomplete record from which they were able to determine only that Lieberman retained an equity interest in Wyoming.com. The law of the case doctrine did not limit the district court to any particular method for determining the value of Lieberman’s equity interest in a conversion action.
Date of conversion and valuation of Lieberman’s equity interest: Based upon the record before the Court which included the cancelled membership certificate, Mossbrook’s testimony that the certificate was in fact cancelled April 16, 1998, and the evidence showing that Wyoming.com paid the $20,000 capital contribution to the district court in the garnishment proceeding, the Court stated it was clear Lieberman was entitled to liquidating distributions as of that same date. Therefore, pursuant to § 17-15-142, the corporation was liable to him for conversion. The Court stated that the prior Lieberman decisions were never intended to suggest that Lieberman had any legitimate claim to a shareholder interest in the successor corporation.
The Court determined the value of Lieberman’s interest at the time and place of the conversion based upon an independent appraiser’s value from April 1998. Lieberman’s equity interest was $100,000.
Breach of fiduciary duty: Lieberman alleged the Mossbrooks owed him a fiduciary duty of good faith and fair dealing to provide him with K-1 reports and tax returns. The Court stated that after Lieberman withdrew and Wyoming.com returned his capital contribution, he had no right to K-1 reports and tax returns.
Judgment against the members/shareholders individually and joint and several liability: There was nothing in the record to support a determination that the separate identity of Wyoming.com or the corporation should have been disregarded and the members or shareholders held individually liable. Both the Wyoming and the Federal rules allow the dismissal or addition of parties to an action even after the trial has concluded. The Court stated that adding Wyoming.com prejudiced no one and that no grounds existed for piercing the corporate veil. The shareholders have no liability to Lieberman, jointly, severally or otherwise.
Discovery sanctions: In considering whether a district court abused its discretion, the ultimate issue is whether or not the court could reasonably conclude as it did. The Mossbrooks’ actions with regard to the documents and the deposition did not comply with the district court’s order. The order granting sanctions was affirmed.

Conclusion: Lieberman’s 2005 complaint was not barred by the statute of limitations. The Court’s decisions in Lieberman I, II and III did not establish law of the case precluding the district court from considering the status of Lieberman’s equity interest in light of his conversion claim and evidence presented for the first time after the earlier decisions were rendered. Given the evidence establishing that Lieberman’s membership and equity interest in Wyoming .com ended in 1998, and the applicable statutory and contractual provisions, the district court’s judgment valuing his equity interest as of 2001 was erroneous as a matter of law.
The Mossbrooks presented evidence that the value of Lieberman’s interest was $100,000 less than the $27,965 they returned to him. The Court concluded from the record that the evidence supported Mossbrooks’ calculation and held that Lieberman was entitled to a judgment of $72,035 plus interest. Because the parties against whom he brought his claims were not liable, the corporation must be substituted as the defendant when the judgment was entered. The Court affirmed the district court’s sanctions against the Mossbrooks, although the order must be amended on remand to reflect that Wyoming.com was the responsible party.

Affirmed in part, reversed in part.

J. Kite delivered the decision.

Link: http://tinyurl.com/qm74tg .

[SPECIAL NOTE: This opinion uses the "Universal Citation." It was given an "official" citation when it was issued. You should use this citation whenever you cite the opinion, with a P.3d parallel citation. Please note when you look at the opinion that all of the paragraphs are numbered. When you pinpoint cite to a quote, you should cite to this paragraph number rather than to any page number. If you need assistance in putting together a citation using the Universal Citation form, please contact the Wyoming State Law Library.]

Wednesday, May 13, 2009

Summary 2009 WY 64

Summary of Decision issued May 13, 2009

Summaries are prepared by Law Librarians and are not official statements of the Wyoming Supreme Court.

Case Name: Piña v. Christensen, MD

Citation: 2009 WY 64

Docket Number: S-07-0295

Appeal from the District Court of Park County, the Honorable Wade E. Waldrip, Judge.

Representing Appellants Piña: James E. Fitzgerald of the Fitzgerald Law Firm, Cheyenne, Wyoming.

Representing Appellee Christensen: Scott P. Klosterman of Williams, Porter, Day & Neville, PC, Casper, Wyoming.

Facts/Discussion: The Piñas brought an action against Dr. Christensen for medical malpractice. The Piñas appeal arguing the jury instructions misled the jury as to the appropriate standard of care.

Propriety of challenged instruction: The jury instruction at issue was: “Before you find that Dr. Christensen was negligent in his care and treatment of Mrs. Piña, you must first find, by a preponderance of the evidence, that he failed to act in accordance with the standard of care adhered to by the American Board of Urology.” The Piñas argued the instruction was erroneous because it required them to submit proof of written, clear-cut standards of care adopted by the American Board of Urology and alleged on appeal the Board did not have any such written standards.
The statute was a correct statement of law reflecting the legislative directive that a medical specialist should be held to national standards of care and treatment appropriate to the specialty. Nothing in the statutory language suggests a national board must adhere to written, clear-cut standards of care. Given the evidence at trial and the jury instructions as a whole, the Court did not believe the jury was confused as to the applicable standard of care. The Court stated that a jury instruction quoting § 1-12-601 does not provide the same clarity as instructions based on Wyoming Civil Pattern Jury Instructions 14.02 and 14.03.

Conclusion: Under the specific facts of the case, the district court did not err in giving the objected to jury instruction. However, the use of the instruction is disfavored.

Affirmed.

J. Golden delivered the decision.

Link: http://tinyurl.com/ouuw4o .

[SPECIAL NOTE: This opinion uses the "Universal Citation." It was given an "official" citation when it was issued. You should use this citation whenever you cite the opinion, with a P.3d parallel citation. Please note when you look at the opinion that all of the paragraphs are numbered. When you pinpoint cite to a quote, you should cite to this paragraph number rather than to any page number. If you need assistance in putting together a citation using the Universal Citation form, please contact the Wyoming State Law Library.]

Tuesday, May 12, 2009

Summary 2009 WY 63

Summary of Decision issued May 12, 2009

Summaries are prepared by Law Librarians and are not official statements of the Wyoming Supreme Court.

Case Name: Luhm v. Board of Trustees of Hot Springs County Sch. Dist. No. 1

Citation: 2009 WY 63

Docket Number: S-07-0227

Appeal from the District Court of Hot Springs County, the Honorable John R. Perry, Judge.

Representing Appellant Luhm: Patrick E. Hacker, Gregory P. Hacker, Erin M. Kendall of Patrick E. Hacker, PC, Cheyenne, Wyoming.

Representing Appellee Hot Springs: Tracy J. Copenhaver of Copenhaver, Kath, Kitchen & Kolpitcke, LLC, Powell, Wyoming.

Facts/Discussion: Luhm worked for the Hot Springs County School District as a guidance counselor. In 2006, Luhm filed a complaint alleging the School District terminated her from her job with the district in a manner that violated law. Luhm claimed her termination was contrary to the spirit and letter of the Wyoming Teacher Employment Law (WTEL). Each year of her employment, Luhm signed a contract titled “non-teaching contract” with the School District.

Was Luhm a teacher as defined by the WTEL: The Court stated that Luhm was unambiguously not a teacher by contract, so the question was whether she was a teacher by statute. A teacher is defined as any person employed under contract by the board of trustees of a school district as a certified professional employee. Luhm argued she was certificated by the Professional Teaching Standards Board (PTSB) qualifying her as a certified professional employee and therefore making her a de jure teacher. The Court believed that the WTEL required all teachers to be certified professional employees but did not envisage that all certified professional employees be considered teachers. The Court noted their holding in Seyfang v. Board of Trustees of Washakie County Sch. Dist. No. 1 applied to the instant case. The term “teacher” under the WTEL envisages certified professional employees engaged in the teaching profession. The Court noted that none of Luhm’s responsibilities involved teaching students a specific recognized academic subject. Consequently, it decided there was no question of material fact.

Conclusion: The Court agreed that a guidance counselor was not a teacher but rather a certified professional employee who provided auxiliary professional services. Luhm, certified as a guidance counselor and social worker was not a teacher within the meaning of the WTEL and therefore was not entitled to its protections.

Affirmed.

J. Golden delivered the decision.

J. Hill dissenting, joined by J. Kite: J. Hill stated he did not agree with the majority that the district court was correct in determining there were no genuine issues of material fact in the case. He also did not agree that Luhm was not a “teacher” as the word is used in Wyo. Stat. Ann. § 21-7-102(a)(vii). The Justices would have reversed the summary judgment and remanded to the district court for full development of a trial record.

Link: http://tinyurl.com/qndw8a .

[SPECIAL NOTE: This opinion uses the "Universal Citation." It was given an "official" citation when it was issued. You should use this citation whenever you cite the opinion, with a P.3d parallel citation. Please note when you look at the opinion that all of the paragraphs are numbered. When you pinpoint cite to a quote, you should cite to this paragraph number rather than to any page number. If you need assistance in putting together a citation using the Universal Citation form, please contact the Wyoming State Law Library.]

Summary 2009 WY 62

Summary of Decision issued May 7, 2009

Summaries are prepared by Law Librarians and are not official statements of the Wyoming Supreme Court.

Case Name: Wm. F. West Ranch, LLC v. Tyrell; Pennaco Energy Inc. v. Wm F. West Ranch, LLC

Citation: 2009 WY 62

Docket Number: S-08-0161; S-08-0162

Appeal from the District Court of Laramie County, the Honorable Peter G. Arnold, Judge.

Representing Wm West Ranch (West): Kate M. Fox and J. Mark Stewart of David & Cannon, LLP, Cheyenne, Wyoming; Sarah Klahn of White & Jankowski, Denver, Colorado.

Representing Pennaco: Brent R. Kunz of Hathaway & Kunz, PC, Cheyenne, Wyoming; John C. Martin of Patton Boggs LLP, Washington, DC; Scott P. Klosterman and Margo Harlan-Sabec of Williams, Porter, Day & Neville, PC, Casper, Wyoming.

Representing Tyrrell and State Engineer and Board of Control: Bruce A. Salzburg, Attorney General; Jay Jerde, Deputy Attorney General; Peter K. Michael, Senior Assistant Attorney General; Marion Yoder, Senior Assistant Attorney General.

Facts/Discussion: West Ranch and the Turners (West) appealed the district court’s determination that it did not have jurisdiction over their declaratory judgment action challenging the Wyoming State Engineer’s and Wyoming Board of Control’s (the State) administration of underground water produced and stored as part of the process of extracting coal bed methane (CBM). The district court concluded that the plaintiffs had not presented a justiciable controversy because the issues were currently being considered by the legislative and executive branches of state government. The Court noted the dispositive issue to be whether the plaintiffs sufficiently articulated any justiciable claim under Wyoming’s Declaratory Judgments Act.

Jurisdiction – Uniform Declaratory Judgments Act: The Act does not extend the jurisdiction of the courts. It defines the rights which may be subject to declaration under the act and the parties who may seek a declaration of their rights. The Court noted that in Brimmer v. Thomson, it adopted a four-part test for determining whether a party presented a justiciable controversy to maintain a declaratory judgment action in Wyoming. The test required the parties have existing and genuine rights or interests; the controversy be one upon which the judgment of the court may effectively operate as distinguished from a debate evoking a purely political, administrative, philosophical or academic conclusion; it must be a controversy the judicial determination of which will have the force and effect of a final judgment in law or decree in equity upon rights, status or legal relationships of the parties; and the proceedings must be genuinely adversary in character and not mere disputation. Declaratory judgment is not available in administrative cases when the question should initially be decided by the agency. An agency created by the legislature to perform a specific function is considered to have special expertise.
Application of Declaratory Judgment Law to Plaintiff’s Complaint: The Brimmer elements require West and Turner to allege that they have a tangible interest which has been harmed and that a judicial decision in their favor will effectively remedy the harm. In the context of the case, West and Turner needed to allege that the State had a constitutional or statutory duty to undertake some function in an actual way; and a declaration that the State had the responsibility to undertake that specific function would effectively remedy their harm. While West and Turner do allege the State has generally failed to comply with certain statutory and constitutional duties in administering CBM water and that they have a genuine interest in that they won property that has been harmed by CBM water, they do not allege facts that connect the asserted general deficiencies win the State’s administration of CBM water to direct harm they have suffered or will suffer in the future. They did not allege facts that would indicate a declaratory judgment in accordance with their particular requests for relief would have an actual effect on their properties. While the Court has recognized a more lenient definition of justiciability in matters of great public importance, the facts alleged in the cases demonstrated that public importance alone was not sufficient to establish justiciability.
Right to Intervene: The Court did not consider the question of intervention because it affirmed the district court’s dismissal of the complaint.

Conclusion: The plaintiffs’ claims were too general to be justiciable. They did not connect the alleged deficiencies in the State’s administration of water to a direct harm they have suffered. Nor did they make a sufficient showing that a ruling by the court would have an actual effect on them. Moreover, administrative remedies are available to the plaintiffs to address many of their complaints. Where administrative procedures are provided, the plaintiffs must utilize those procedures before bringing a declaratory judgment action.

Affirmed.

J. Kite delivered the decision.

Link: http://tinyurl.com/dm5wwn .

[SPECIAL NOTE: This opinion uses the "Universal Citation." It was given an "official" citation when it was issued. You should use this citation whenever you cite the opinion, with a P.3d parallel citation. Please note when you look at the opinion that all of the paragraphs are numbered. When you pinpoint cite to a quote, you should cite to this paragraph number rather than to any page number. If you need assistance in putting together a citation using the Universal Citation form, please contact the Wyoming State Law Library.]

Summary 2009 WY 61

Summary of Decision issued May 1, 2009

Summaries are prepared by Law Librarians and are not official statements of the Wyoming Supreme Court.

Case Name: Yoeuth v. State; Loo v. State

Citation: 2009 WY 61

Docket Number: S-08-0136; S-08-0170

Appeal from the District Court of Carbon County, the Honorable Wade E. Waldrip, Judge.

Representing Appellant Yoeuth: Diane M. Lozano, State Public Defender; Tina N. Kerin, Appellate Counsel; Eric M. Alden, Senior Assistant Appellate Counsel.

Representing Appellant Loo: Dion J. Custis, Cheyenne, Wyoming.

Representing Appellee State: Bruce A. Salzburg, Attorney General; Terry L. Armitage, Deputy Attorney General; D. Michael Pauling, Senior Assistant Attorney General; Graham M. Smith, Assistant Attorney General.

Facts/Discussion: Loo and Yoeuth challenged the district court’s denial of their motions to suppress evidence obtained during a traffic stop and subsequent search of the vehicle’s trunk.

Mr. Loo, the initial stop: Loo and Yoeuth moved to suppress the evidence (thirty-seven pounds of marijuana) found when the trooper searched the trunk of the rental car that Loo was driving. Loo maintained that he suffered violations of his rights under both Article 1, Section 4 of the Wyoming Constitution and under the Fourth Amendment to the United States Constitution. The Court must determine whether under all the circumstances, the trooper’s actions were reasonable and in compliance with state and federal constitutional prohibitions against unreasonable searches and seizures. The test is whether the initial stop is justified and the focus is on a fact-based reasonableness inquiry. The district court determined that the trooper was justified in stopping Loo based on the specific fact that he has observed a traffic violation.
The initial detention: The trooper’s questions were limited to the topics of Loo’s right to operate the car and their travel plans. Based on the findings, the district court concluded the detention was reasonable both under Wyoming and United States law.
The second round of questioning: At the end of the initial detention, the trooper informed Loo that he was free to go and asked if Loo would answer a few more question and he agreed. The district court determined the consent to be voluntary and that the questioning did not violate his rights. The Court agreed.
The canine sniff: The Court reviewed the list of factors articulated by the trooper as giving rise to reasonable suspicion including a perfume odor that dissipated over time; the existence of two rental agreements; Loo’s unusually high nervousness; the drug detection dog sniffing Loo when he entered the patrol car; and the trooper’s knowledge that traffickers often rent more than one car. Based on the factors, the Court concluded that the trooper had reasonable and articulable suspicions of ongoing criminal activity.
The search of the trunk: Under the United States Constitution, when a trained drug dog alerts during an exterior sniff of a vehicle, there is probable cause to search that vehicle.
Ms. Yoeuth, standing as a passenger: Yoeuth argued the district court incorrectly ruled that she did not have standing to pursue a direct challenge to the validity of the trooper’s actions which wrongfully denied her the opportunity to assert the trooper violated her constitutional rights. The Court noted that a passenger who is rightfully present in a vehicle has a reasonable expectation of privacy and therefore has standing to challenge governmental invasion of that expected privacy. A review of the transcript suggested that the district court was not making an oral ruling that she lacked standing but was seeking clarification of whether Yoeuth asserted standing base upon alleged violation of her own rights, or of the rights of Loo.
Loss of standing by denial of ownership: The district court ruled that Yoeuth lacked standing to challenge the validity of the search of the trunk because she renounced any interest in the trunk by stating that she did not put anything in the trunk. Yoeuth argued that her statement was not a sufficiently unequivocal denial of ownership to establish that she abandoned her expectations of privacy in the trunk or its contents. The Court discussed Garzon and Andrews noting that Yoeuth’s circumstances were closer to those in Garzon. The Court determined that her comment did not amount to an unequivocal denial of ownership and concluded that she did have standing to challenge the constitutionality of the search of the trunk.
Opportunity to assert her constitutional challenges: The district court found the trooper had reasonably articulable suspicions of illegal activity allowing him to detain Loo during the dog sniff. The same suspicions applied to Yoeuth. The dog’s alert at the trunk provided the trooper with probable cause. That conclusion applies equally to Loo and Yoeuth. Yoeuth had a full opportunity to present the district court with all the facts and arguments in support of her motion to suppress. But she provided no basis for the district court to reach a different result than it did for Loo.

Conclusion: The Court affirmed the district court’s denial of the motions to suppress in both cases.

Affirmed.

J. Burke delivered the decision.

Link: http://tinyurl.com/cxzkm7 .

[SPECIAL NOTE: This opinion uses the "Universal Citation." It was given an "official" citation when it was issued. You should use this citation whenever you cite the opinion, with a P.3d parallel citation. Please note when you look at the opinion that all of the paragraphs are numbered. When you pinpoint cite to a quote, you should cite to this paragraph number rather than to any page number. If you need assistance in putting together a citation using the Universal Citation form, please contact the Wyoming State Law Library.]

Summary 2009 WY 60

Summary of Decision issued May 1, 2009

Summaries are prepared by Law Librarians and are not official statements of the Wyoming Supreme Court.

Case Name: Sutton v. State

Citation: 2009 WY 60

Docket Number: S-08-0249

Order Affirming the Judgment and Sentence of the District Court

The matter came before the Court on its own motion following notification that Sutton failed to file a pro se brief within the time allotted. The Court entered its “Order Granting Permission for Court Appointed Counsel to Withdraw on March 10, 2009. That Order provided that the Judgment and Sentence would be affirmed unless Sutton filed a brief prior to April 27, 2009.

Affirmed.

C.J. Voigt delivered the decision.

Link: http://tinyurl.com/ccualq .

[SPECIAL NOTE: This opinion uses the "Universal Citation." It was given an "official" citation when it was issued. You should use this citation whenever you cite the opinion, with a P.3d parallel citation. Please note when you look at the opinion that all of the paragraphs are numbered. When you pinpoint cite to a quote, you should cite to this paragraph number rather than to any page number. If you need assistance in putting together a citation using the Universal Citation form, please contact the Wyoming State Law Library.]

Thursday, May 07, 2009

Free Online Seminar: BriefTools & CiteAdvisor: An Integrated Document Review System

For those of you who have Westlaw access, here's a free training opportunity from Westlaw. And if you don't have Westlaw access in your office or home, you can use the law library's free public Westlaw access!



Sign up for this informative online seminar that will illustrate how to use West BriefTools and West CiteAdvisor to quickly and easily produce accurate and perfectly formatted legal documents.

Some tips you'll learn include:
  • Assure your brief cites only good law
  • Locating and leveraging internal documents that are relevant to your case or topic
  • Give yourself an advantage in monitoring the status of authority that your opposition cites
  • How to format legal citations within briefs, motions, decisions, opinions, and law review articles
  • Selecting your jurisdiction and the formatting rules (i.e. Bluebook) you want to follow
  • Building and inserting tables of authorities
Plus, since it's a live, interactive seminar, you'll have a chance to ask questions. Please feel free to forward this e-mail to colleagues that may be interested in the session.

Registration is simple. Select a day and time that works best for you, then click on it to sign up:

Webinar Times
Tuesday, May 5, 2009, 10AM Central Standard Time
Thursday, May 7, 2009, 2PM Central Standard Time

If you're not available for this seminar, or if you'd prefer a one-on-one teleconference regarding your specific research needs, please call 1-800-328-0109 to speak with your dedicated attorney trainer for training.

Free Online Seminar: Enhance Your Research Experience with Customizable Westlaw

For those of you who have Westlaw access, here's a free training opportunity from Westlaw. And if you don't have Westlaw access in your office or home, you can use the law library's free public Westlaw access!


Westlaw has a whole new level of customization to enhance your Westlaw experience! Now you can build and rearrange the content on your Westlaw tabs so it fits your workflow. It's just another way Westlaw helps you quickly access the information you need so you get better results faster.Sign up for this informative online seminar that will show you how to do the following to customize your Westlaw experience:
  • Drag and drop databases, database groups, and tabs so the ones you use most often are right where you want them.
  • Add or delete content, rename tabs, rename database groups, select display options and copy "shortcut" tools to another tab.
  • Create customized tabbed pages from scratch
  • E-mail personalized pages to colleagues and customers
  • Write on-screen sticky notes and reminders while doing your research

Plus, since it's a live, interactive seminar, you'll have a chance to ask questions. Please feel free to forward this e-mail to colleagues that may be interested in the session.

Registration is simple. Select a day and time that works best for you, then click on it to sign up.

Webinar Times
Wednesday, May 13, 2009 @ 10:00 a.m. (Central Time)
Friday, May 15 @ 2:00 p.m. (Central Time)

Please register by May 12.

If you're not available for this seminar, or if you'd prefer a one-on-one teleconference regarding your specific research needs, please call 1-800-328-0109 to speak with your dedicated attorney trainer for training.

HeinOnline Webinars

HeinOnline is available in almost all Wyoming county public libraries, as well as at the Wyoming State Library and the law library.


From the HeinOnline Update April 2009:

Last month we hosted our first Webinar and concentrated on "Getting Started" in HeinOnline. We had more than 100 attendees and received a lot of great feedback. If you missed the webinar and wish to view it, we have posted a link to the recording at http://heinonline.org/wiki/index.php/HeinOnline:WebinarGettingStarted, or you can view it by clicking here.

Our next webinar is scheduled for Wednesday, May 13, 2009 from 2:00 p.m.-3:00 p.m EDT. This webinar will focus on using and searching HeinOnline's Law Journal library. We will discuss the following:

  • How to quickly pull up a journal article when you have a citation
  • How to search for a journal article by article name
  • How to search for articles written by a specific author
  • Browsing or searching by subject, state, or country
  • Overview of indexes and finding aids available
  • How to use the full power of Hein's ScholarCheck tool to connect citations and view citation analysis
  • How to find coverage information for a journal title
  • And much more!
Click here to register for the webinar, https://www2.gotomeeting.com/register/760984123.

For more information or if you have any questions, please visit our Webinars page on the wiki at http://heinonline.org/wiki/index.php/HeinOnline:Webinars, or email us at marketing@wshein.com.

Check out our tags in a cloud (from Wordle)!