Justia Wyoming Supreme Court Opinion Summaries

Articles Posted in Civil Rights

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The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree sexual abuse of a minor, holding that Defendant was not entitled to relief on any of his allegations of error. Defendant was charged with three counts of first-degree sexual abuse of a minor. Defendant was convicted on counts I and III and acquitted on count II. Defendant appealed his conviction on count I, claiming, among other things, that the trial court committed reversible error because the jury instructions contained identical elements for counts I and II with nothing to differentiate the counts and because the verdict form also failed to distinguish between the two counts. The Supreme Court reversed, holding (1) Defendant waived review of his challenge regarding the description of counts I and II under the invited error doctrine; (2) the evidence was sufficient to convict Defendant on count I; and (3) Defendant's counsel was not ineffective. View "Jackson v. State" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of aggravated kidnapping, sexual abuse of a minor in the first degree, and sexual abuse of a minor in the second degree and sentencing Defendant to a term of eighty to 115 years in prison, holding that Defendant's claims of error were unavailing. Specifically, the court held (1) the district court did not err in denying Defendant's motion for a new trial because Defendant failed to show that his trial counsel was constitutionally ineffective; (2) the district court did not abuse its discretion in admitting other acts evidence under Wyo. R. Evid. 404(b); (3) there was sufficient evidence to sustain Defendant's aggravated kidnapping conviction; and (4) double jeopardy principles did not require the aggravated kidnapping and first-degree sexual abuse of a minor sentences to be merged. View "Winters v. State" on Justia Law

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The Supreme Court affirmed the order of the district court dismissing Appellant's complaint against the Wyoming Department of Corrections (WDOC) asking that the WDOC recognize Humanism as a religion, holding that the district court correctly dismissed Appellant's complaint as moot. Appellant, an inmate in the custody of the WDOC, brought this complaint under 42 U.S.C. 1983 seeking declaratory and injunctive relief and seeking money damages against the WDOC's director and its deputy administrator in their individual capacities. After Appellant filed his complaint, the WDOC officially recognized Humanism as a religion. Thereafter, the district court dismissed Appellant's complaint and denied Appellant's motion for attorney fees. The Supreme Court affirmed, holding (1) the voluntary cessation exception to the mootness doctrine has not been adopted in Wyoming; (2) Defendants were entitled to qualified immunity; and (3) Appellant was not a "prevailing party" under 42 U.S.C. 1988. View "Guy v. Lampert" on Justia Law

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The Supreme Court affirmed Defendant's convictions of one count each of felony stalking and burglary, holding that Defendant was not entitled to relief on any of his allegations of error. Specifically, the Court held (1) Defendant was not prejudiced when his counsel failed to file a motion to suppress statements Defendant made without receiving a Miranda warning; (2) review of Defendant's claim that the district court erred in failing to suppress Defendant's statements made without a Miranda warning was precluded; (3) the district court did not abuse its discretion in admitting body camera footage of Defendant's traffic stop; and (4) Defendant's convictions were supported by sufficient evidence. View "Bittleston v. State" on Justia Law

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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