Articles Posted in Civil Rights

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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

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The Supreme Court reversed Appellant's convictions, holding that the record did not show a factual basis for Appellant's guilty plea as to counts two through eleven, and therefore, Appellant was prejudiced by her trial counsel’s deficient performance in advising her to plead guilty to ten felony counts under Wyo. Stat. Ann. 42-4-111(a) without a factual basis to satisfy the felony threshold. Appellant pled guilty to one felony count of Medicaid fraud related to improper record-keeping, ten felony counts of Medicaid fraud for making false or misleading statements in Medicaid claims when the value of the medical assistance is $500 or more, and two counts of felony forgery. Appellant filed a Wyo. R. App. P. 21(a) motion to withdraw her pleas due to ineffective assistance, arguing that the State unlawfully charged her with counts two through eleven and that her trial counsel provided ineffective assistance because he did not challenge those charges. Instead, trial counsel advised Appellant to accept a plea agreement under which Appellant pled guilty to all charges. The Supreme Court reversed, holding that there was no factual basis for Appellant’s guilty plea as to the ten felony counts, and trial counsel provided ineffective assistance by advising Appellant to accept the plea agreement. View "Mellott v. State" on Justia Law

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The Supreme Court affirmed Defendant’s conviction of three controlled substance charges, holding that the district court did not err by denying Defendant’s motion to suppress evidence discovered during a search of Defendant’s vehicle. On appeal, Defendant argued that a law enforcement officer violated his rights under the Fourth Amendment when he detained Defendant for a dog sniff and searched Defendant’s pickup truck without a warrant. The Supreme Court disagreed, holding (1) the officer’s initial stop of Defendant was justified because he was speeding; (2) the officer had reasonable, articulable suspicion that Defendant was engaged in drug crimes, justifying his further detention; and (3) the automobile exception to the warrant requirement applied to Defendant’s pickup. View "Pier v. State" on Justia Law

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The Supreme Court affirmed Defendant’s conviction of one count of first degree sexual assault of minor, holding that the district court erred in providing an ex parte response to a juror’s note, but the error was harmless, and that Defendant received effective assistance of counsel. Specifically, the Court held (1) the district court erred when it responded to a juror note expressing confusion over DNA testimony without informing either party of the juror note and the court’s response to it, but the error was harmless; and (2) Defendant did not receive ineffective assistance of counsel based on an alleged conflict or interest or on counsel’s purported failure to adequately pursue a theory of intentional secondary DNA transfer. View "Wall v. State" on Justia Law