Megan B. Golden v. Todd A. Guion
2016 WY 54
| Wyo. | 2016Background
- Megan Golden and Todd Guion divorced in 2012; the decree split real and personal property and ordered Guion to store Golden’s awarded personal property and pay $90,000 for real property equity.
- Golden repeatedly alleged Guion damaged, destroyed, or withheld her personal property; the divorce trial addressed those claims and the court declined to adjust the property division on that basis.
- Multiple contempt proceedings followed: an August 2012 oral denial of Golden’s contempt motion (no written order entered), a 2013 contempt finding against Golden for refusing to sign a quitclaim deed, and a February 11, 2015 order awarding Guion damages after contempt proceedings and denying Golden relief on the personal-property claims.
- Golden filed motions in 2015: a motion to vacate the February 2015 order (filed Feb. 26, 2015) and a May 11, 2015 motion for rehearing of the 2012 contempt motion (arguing the oral denial was void). She also pursued prior appeals, including Golden I, where this Court summarily affirmed and awarded fees to Guion.
- The district court (Aug. 31, 2015) denied Golden’s rehearing and vacatur motions and granted Guion Rule 11 sanctions for repeated, meritless filings regarding the personal-property claims.
- On appeal the Supreme Court of Wyoming: dismissed two appeals for lack of jurisdiction (untimely notices after motions were "deemed denied"), affirmed the Rule 11 sanctions, and awarded appellate-sanction relief to Guion under W.R.A.P. 10.05.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction: Were Golden's appeals timely under Rule 6(c)(2)'s "deemed denied" rule? | Golden argued she was entitled to rehearing and vacatur and filed notices of appeal after the district court's Aug. 31, 2015 order. | Guion argued the motions were "deemed denied" after 90 days and Golden failed to file notices within 30 days, so appeals are untimely. | Appeals in S-15-0247 and S-15-0248 dismissed for lack of jurisdiction; notices were untimely under Rule 6(c)(2) and Paxton. |
| Rule 11: Did the district court abuse its discretion by awarding sanctions? | Golden contended her motions were legitimate efforts to obtain relief on personal-property claims and Rule 11 was inappropriate. | Guion argued the motions were repetitive, meritless, and intended to harass; Rule 11 sanctions were justified. | Affirmed: district court did not abuse its discretion; Golden repeatedly relitigated matters barred by res judicata and filed baseless motions. |
| W.R.A.P. 10.05 sanctions: Are appellate sanctions warranted? | Golden offered no timely or cogent appellate showing and failed to comply with appellate rules. | Guion requested fees and costs for defending frivolous/untimely appeals and procedural deficiencies. | Granted: Court awarded Guion entitlement to reasonable attorney fees and costs on appeal under W.R.A.P. 10.05; amount to be determined. |
Key Cases Cited
- Golden v. Guion, 299 P.3d 95 (Wyo. 2013) (prior appeal where Court affirmed and awarded fees)
- Paxton Resources, LLC v. Brannaman, 95 P.3d 796 (Wyo. 2004) (interpreting Rule 6(c)(2) "deemed denied" deadline for filing appeals)
- Waldron v. Waldron, 349 P.3d 974 (Wyo. 2015) (timely filing of notice of appeal is jurisdictional)
- Lavitt v. Stephens, 347 P.3d 514 (Wyo. 2015) (standard of review for Rule 11 sanctions: abuse of discretion)
- Harshfield v. Harshfield, 842 P.2d 535 (Wyo. 1992) (res judicata bars relitigation of issues decided in a divorce decree)