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The Supreme Court reversed Defendant’s conviction of aggravated assault and attempted second-degree murder for stabbing her uncle, holding that the district court erred in declining to give the defense’s proposed instruction regarding the duty to retreat in one’s residence. Based upon its conclusion that Defendant was not a resident of her uncle’s home, the district court declined to give Defendant’s proposed castle doctrine instruction to the jury. The Supreme Court held that the district court improperly resolved the disputed factual question of whether Defendant was a resident of her uncle’s home because the question of Defendant’s residence was a factual one. Therefore, the question should have been submitted to the jury. If the jury determined the home to be Defendant’s residence, the district court should have instructed the jury regarding the castle doctrine. Further, the district court erred when it gave an incorrect malice definition and abused its discretion when it prohibited testimony of specific instances of conduct relating to the victim’s character for violence. View "Widdison v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed Defendant’s conviction for first-degree murder, entered after a jury trial. On appeal, Defendant argued that the district court erred in several ways instructing the jury and that the court utilized an improper stepped verdict form. The Supreme Court disagreed, holding (1) any error or confusion that may have existed in the jury instructions regarding the law of self defense could not have prejudiced Defendant; (2) Defendant failed to demonstrate plain error in the district court’s jury instructions regarding the State’s burden of proof regarding a “sudden heat of passion” in voluntary manslaughter; (3) there was no plain error in the verdict form the district court submitted to the jury; and (4) the district court did not commit plain error when it did not provide the jury a definition of “recklessly” or “enhanced recklessness” within the instruction defining malice in second-degree murder. View "Johns v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the judgment of the district court denying Defendant’s pro se motion to correct an illegal sentence pursuant to Wyo. R. Crim. P. 35(a), holding (1) res judicata did not bar Defendant’s Rule 35(a) double jeopardy claim; and (2) the district court properly denied Defendant’s actual innocence and constructive denial of counsel claims on the basis that such claims are not cognizable under Rule 35(a). Defendant pleaded guilty to one count of third degree sexual assault and one count of abuse of a vulnerable adult. Defendant was sentenced to consecutive prison terms. Defendant later filed a motion to correct an illegal sentence. The district court denied the motion. The Supreme Court affirmed, holding (1) because Defendant did not show good cause for failing to raise his double jeopardy claim in earlier proceedings, his claim was barred by res judicata; and (2) Defendant’s remaining claims were not cognizable under a Rule 35(a) motion. View "Hicks v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of three counts of second degree sexual assault of a minor and one count of first degree sexual assault of a minor. The court held (1) the district court did not abuse its discretion in admitting uncharged acts evidence under Wyo. R. Evid. 404(b); and (2) the trial court did not abuse its discretion in applying the rape shield statute to prohibit Defendant from cross-examining one of the victims on her status as a victim in a prior sexual abuse case. View "Moser v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the judgment of the trial court denying Defendant’s motion to suppress evidence obtained as a result of a detention and subsequent search of his vehicle. Defendant was charged with one count of possession of a controlled substance and one count of a controlled substance with intent to deliver. Defendant moved to suppress evidence based on the roadside search of his car, arguing that the initial traffic stop was not justified by reasonable suspicion and that the subsequent detention was unconstitutional. The district court denied the motion to suppress. On appeal, Defendant conceded that the initial stop was justified but challenged the investigative detention. The Supreme Court affirmed, holding that the trial court did not err in denying Defendant’s motion to suppress. View "Harris v. State" on Justia Law

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The Supreme Court affirmed the order of the district court dismissing SH’s complaint against the Campbell County School District seeking to recover damages for injuries she received when she slipped and fell on a school playground. SH, who received special education services in accordance with an Individual Education Plan (IEP), claimed that the Wyoming Governmental Claims Act did not bar her suit against the school district because the IEP was a contract, and therefore, the Act’s exception to immunity for contract claims applied. The district court found that the IEP was not a contract and, accordingly, there was no exception to governmental immunity under the Act. The Supreme Court agreed, holding (1) the IEP is not a contract; and (2) the IEP therefore does not create an exception to the School District’s governmental immunity. View "SH v. Campbell County School District" on Justia Law

Posted in: Personal Injury

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The Supreme Court affirmed the decision of the district court ruling that the Office of Administrative Hearings (OAH) erred in upholding the Wyoming Workers’ Compensation Division’s denial of benefits to Richard Williams. Williams suffered a head injury while working as a well operator. Williams argued that a flash fire started him and caused him to fall backward and strike his head. The Division denied benefits, determining that Williams’ injury did not arise out of an in the course of his employment. The OAH upheld the denial of benefits, finding that Williams and his version of events lacked credibility. The district court reversed, concluding that the OAH decision was contrary to overwhelming medical evidence that Williams injured his head while engaged in work-related activities. The Supreme Court affirmed, holding that Williams offered evidence sufficient to raise a presumption that he suffered a head injury that arose out of his employment and that the Division failed to rebut that presumption. View "State ex rel. Department of Workforce Services, Workers' Compensation Division v. Williams" on Justia Law

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The Supreme Court affirmed the order of the trial court convicting Defendant on a charge of first-degree arson. On appeal, Defendant argued that the district court abused its discretion when, at trial, it admitted evidence of other acts, in violation of Wyo. R. Evid. 404(b). The Supreme Court disagreed, holding (1) the district court did not commit plain error when it conducted its Rule 404(b) Gleason analysis after the disputed Rule 404(b) evidence had been admitted and after the close of the evidence; and (2) the district court did not abuse its discretion when it admitted evidence of other acts at trial. View "Garrison v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the decision of the district court finding that Plaintiffs, two Wyoming citizens, lacked standing to challenge legislation that authorized two construction projects while maintaining a degree of legislative control and that Plaintiffs’ proposed amendment to their complaint would be futile. In their complaint, Plaintiffs alleged that the legislation at issue violated the Wyoming Constitution and that government officials unconstitutionally engaged in a pattern of letting state contracts without competitive bidding or required safeguards. The district court found that Plaintiffs lacked standing and that their proposed amendment to add a third plaintiff who would have alleged economic harm resulting from the contracting practices would be futile. The Supreme Court affirmed, holding (1) Plaintiff lacked standing to bring this lawsuit; and (2) because there was no justiciable controversy, this court declines to address the constitutionality of a statute enacted in 2017 that prohibits naming a legislator in a lawsuit if he or she is sued in an official capacity. View "Allred v. Bebout" on Justia Law

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The Supreme Court affirmed the decision of the district court finding that Plaintiffs, two Wyoming citizens, lacked standing to challenge legislation that authorized two construction projects while maintaining a degree of legislative control and that Plaintiffs’ proposed amendment to their complaint would be futile. In their complaint, Plaintiffs alleged that the legislation at issue violated the Wyoming Constitution and that government officials unconstitutionally engaged in a pattern of letting state contracts without competitive bidding or required safeguards. The district court found that Plaintiffs lacked standing and that their proposed amendment to add a third plaintiff who would have alleged economic harm resulting from the contracting practices would be futile. The Supreme Court affirmed, holding (1) Plaintiff lacked standing to bring this lawsuit; and (2) because there was no justiciable controversy, this court declines to address the constitutionality of a statute enacted in 2017 that prohibits naming a legislator in a lawsuit if he or she is sued in an official capacity. View "Allred v. Bebout" on Justia Law