Feltner v. Casey Family Program
In Feltner v. Casey Family Program, 902 P.2d 206 (Wyo. 1995), Veronica and Doniv Feltner were Jason Feltner's parents. 902 P.2d at 207.
All three Feltners sued the Casey Family Program after a jury convicted nineteen-year-old Jason of fourth-degree sexual assault for having sexual intercourse with a fourteen-year-old girl. 902 P.2d at 207-08.
The Casey Family Program had placed the girl in the Feltners' home for foster care. Id.
The Feltners alleged claims for recovery of damages resulting from Jason's conviction. 902 P.2d at 208.
The district court dismissed the Feltners' claims, and this court affirmed. 902 P.2d at 207.
The Court held public policy precludes a plaintiff from bringing suit to recover for injuries he sustained as a direct result of his own serious violation of the law. 902 P.2d at 208.
The Court also affirmed the dismissal of the parents' claims which arose from their son's criminal conduct. 902 P.2d at 209.
The opinion left the possibility open that independent claims may not be barred on public policy grounds. The Court acknowledged the parents may have had an independent claim for breach of confidentiality which did not derive from Jason's criminal actions. 902 P.2d at 209.
Nevertheless, the Court declined to consider the propriety of the district court's dismissal of that claim because the Feltners did not adequately brief the issue. 902 P.2d at 210.