Articles Posted in Civil Rights

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The Supreme Court affirmed Defendant's conviction of second degree sexual abuse of a minor, third degree sexual abuse of a minor, and contributing alcohol to a minor, holding that the district court did not abuse its discretion in ordering joinder of the sexual abuse charges relating to two victims and did not err in excluding evidence of a prior false sexual abuse allegation by one of the victims. Specifically, the Court held (1) there was no abuse of discretion in the district court's joinder of the offenses for trial where the court reasonably concluded that joinder of the sexual abuse charges was proper under Wyo. R. Crim. P. 8 and 13 and Defendant failed to show that he was prejudiced by the joinder; and (2) the district court did not abuse its discretion or infringe on Defendant's confrontation rights or his right to present a complete defense when it concluded that the victim's prior false statement was not admissible under the rape shield statute. View "Sparks v. State" on Justia Law

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The Supreme Court affirmed the district court's denial of Defendant's motion to suppress, thus affirming Defendant's conviction and sentence, holding that the warrantless detention of Defendant did not violate the Fourth Amendment or Wyo. Const. art. I, 4, 6 and 36. Defendant entered a conditional guilty plea to the charge of possession of marijuana. On appeal, Defendant argued that a police officer unlawfully detained him because he was not violating any laws as he was traveling down the highway and was stopped only pursuant to a temporary roadblock. Defendant asserted that the roadblock was illegal because the officer failed to comply with the statutory requirements set forth in Wyo. Stat. Ann. 7-17-101 through 7-17-103 and that the roadblock otherwise failed to comport with Fourth Amendment standards. The Supreme Court disagreed, holding that the district court properly found that the officer was directing traffic to sure public safety during a rodeo and that Defendant disobeyed the officer's signal to stop. Therefore, the initial stop was legally valid, and the odor of marijuana justified the subsequent search. View "Wright v. State" on Justia Law

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The Supreme Court reversed Defendant's conviction of possession of methamphetamine, holding that Defendant's right to a speedy trial under Wyo. R. Crim. P. 48 was violated when the State failed to bring him to trial within 180 days following his arraignment. On appeal, Defendant argued that his right to a speedy trial was violated and that the trial court erred when it denied his motion to suppress the methamphetamine found in a container inside his truck. The Supreme Court reversed on the speedy trial issue and thus did not address the motion to suppress, holding that Defendant's right to a speedy trial was violated when his trial commenced 194 days after his arraignment. View "Osban v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of one count of possession with intent to deliver marijuana, holding that the district court did not err in denying Defendant's motion to suppress evidence. On appeal, Defendant argued that the district court erred in denying his motion to suppress evidence obtained after a traffic stop, asserting that the stop's "air of pretext" should cause the Court to reevaluate whether a dog sniff to the exterior of a vehicle require "a righter legal framework" under the Wyoming Constitution than the U.S. Constitution. The Supreme Court affirmed, holding that Defendant failed to present cogent argument under the Wyoming Constitution on appeal. View "Gibson v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of felony possession of marijuana and possession with intent to deliver, holding that there was no reversible error in the proceedings below. Specifically, the Supreme Court held (1) the district court did not err in denying Defendant's motion to suppress evidence obtained from a warrantless search; (2) the district court did not commit reversible error in permitting the introduction of improper rebuttal evidence; (3) the prosecutor did not commit prejudicial misconduct through the use of improper evidence and argument; and (4) defense counsel did not provide ineffective assistance by failing to object to the admission of certain rebuttal testimony and the State's alleged improper statements during closing arguments. View "Dixon v. State" on Justia Law

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The Supreme Court affirmed Defendant's drug-related convictions, holding that the district court did not err by denying Defendant's motion to suppress evidence or his motion to dismiss for lack of a speedy trial and that sufficient evidence supported Defendant's conviction of felony possession of methamphetamine in a liquid form, as contemplated by Wyo. Stat. Ann. 35-7-1031. Specifically, the Supreme Court held (1) Defendant's motion to suppress, which challenged the validity of the search warrant, was properly denied; (2) Defendant was not denied his right to a speedy trial under Rule 48 of the Wyoming Rules of Criminal Procedure or the Sixth Amendment of the United States Constitution; and (3) sufficient evidence supported the jury's finding the jury's finding that the liquid contained in Defendant's water pipe, which tested positive for methamphetamine, constituted "a controlled substance in liquid form" under the plain language of section 35-7-1031(c)(i)(B). View "Mathewson v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of second-degree murder, holding that the district court did not commit prejudicial error during the proceedings below and that Defendant did not receive ineffective assistance of trial counsel. Specifically, the Court held (1) the district court did not err in instructing the jury, or where it did err, the error was not prejudicial; (2) the district court did not abuse its discretion in excluding testimony that the victim made previous statements indicating that he wanted to get into a fight; (3) the prosecutor committed misconduct by suggesting that Defendant had the burden of proof on certain issues relating to his self-defense claim, but Defendant failed to show material prejudice; and (4) the district court correctly found that Defendant’s trial counsel did not provide ineffective assistance. View "Farrow v. State" on Justia Law

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The Supreme Court affirmed Defendant’s conviction of one count of third-degree sexual assault, holding that Defendant was not denied her right to due process of law under the Fifth and Fourteenth Amendments to the United States Constitution or under Wyo. Const. art. I, 6,7, and 36. On appeal, Defendant argued, inter alia, that Wyo. Stat. Ann. 6-2-304(a)(iii) and 6-2-303(a)(vii) were facially invalid because they were facially overbroad. The Supreme Court affirmed, holding (1) the statutes at issue are not facially overbroad in violation of the Fourteenth Amendment; and (2) the statutes at issue are not overly broad in violation of Wyo. Const. art. I, 6, 7, and 36. View "Sheesley v. State" on Justia Law

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The Supreme Court affirmed the judgment of the Unemployment Insurance Commission denying Appellant’s application for unemployment insurance after the City of Gillette terminated her employment, holding that there was substantial evidence to support the Commission’s determination that Appellant engaged in misconduct with her work and that the City did not violate Appellant’s First Amendment rights when it terminated her employment. The Commission denied Appellant’s claim for benefits after concluding that the City discharged Appellant because she violated several employer policies when she provided certain work-related confidential information to persons authorized to see that information. The Supreme Court affirmed, holding (1) the Commission had substantial evidence to conclude that Appellant committed misconduct connected with her work; and (2) the City did not infringe on Appellant’s First Amendment rights when it dismissed her for constitutionally protected speech. View "Mahoney v. City of Gillette" on Justia Law

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The Supreme Court affirmed Defendant’s conviction of delivery of a controlled substance, holding that Defendant’s failure to file a pretrial motion to suppress identification evidence precluded this Court’s review of Defendant’s due process claim. On appeal, Defendant argued that his right to due process was violated when the district court admitted into evidence a witness identification that was based on a single photo, rather than a photo array. The Supreme Court affirmed the judgment, holding (1) a defendant’s failure to assert an objection or defense through a pretrial motion required by Wyo. R. Crim. P. 12(b)(3) is a bar to appellate review of a due process claim unless good cause is shown for the defendant’s failure to make the required finding; and (2) because Defendant did not file required motion to suppress the identification evidence against him required by Rule 12(b)(3) and did not show good cause for that failure, Defendant waived appellate review of his claim. View "Rodriguez v. State" on Justia Law