Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence that led to Defendant’s conviction for marijuana possession.Corporal Bradley Halter stopped Defendant for a traffic violation. When Defendant attempted to walk away from the traffic stop, Corporal Halter handcuffed Defendant. Because Defendant smelled of marijuana and was impaired, Corporal conducted a search of Defendant’s person, which produced methamphetamine, and, after a subsequent search, marijuana and hashish. After the denial of his motion to suppress, Defendant entered a conditional plea to the possession of marijuana. The Supreme Court affirmed, holding that Corporal Halter’s seizure of the methpahetamine and subsequent search was supported by both the plain feel doctrine and by standard probable cause considerations. View "Maestas v. State" on Justia Law

The Supreme Court affirmed the district court’s order denying Appellant’s motion to suppress the marijuana Trooper Aaron Kirlin discovered in Appellant’s possession during a traffic stop on Interstate 80.Appellant pleaded guilty to possession of marijuana, preserving his right to appeal the district court’s denial of his motion to suppress. On appeal, Appellant argued that Trooper Kirlin unlawfully detained him beyond the original purpose of the traffic stop in violation of his Fourth Amendment rights. The Supreme Court disagreed, holding that the district court did not err in determining that Trooper Kirlin’s extended contact with Appellant was a consensual encounter that did not violate the Fourth Amendment. View "Kennison v. State" on Justia Law

The Supreme Court remanded this case for a new hearing under Batson v. Kentucky, 476 U.S. 79 (1986), holding that the district court clearly erred by allowing the State to exercise a peremptory challenge to exclude an African American from the jury. The record supported the validity of only one of the prosecutor’s race-neutral reasons for his peremptory challenge and did not show that the district court would credit this reason alone. Specifically, one of the prosecutor’s two explanations for the peremptory challenge upon which the district court relied failed, and the record did not show that the district court would find that the prosecutor was motivated solely by the valid grounds. Therefore, the case must be remanded for a new Batson hearing in which the district court must reassess the prosecutor’s credibility in light of the discrepancy between the record and his explanation. View "Roberts v. State" on Justia Law

The Supreme Court remanded this case for a new hearing under Batson v. Kentucky, 476 U.S. 79 (1986), holding that the district court clearly erred by allowing the State to exercise a peremptory challenge to exclude an African American from the jury. The record supported the validity of only one of the prosecutor’s race-neutral reasons for his peremptory challenge and did not show that the district court would credit this reason alone. Specifically, one of the prosecutor’s two explanations for the peremptory challenge upon which the district court relied failed, and the record did not show that the district court would find that the prosecutor was motivated solely by the valid grounds. Therefore, the case must be remanded for a new Batson hearing in which the district court must reassess the prosecutor’s credibility in light of the discrepancy between the record and his explanation. View "Roberts v. State" on Justia Law

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

The Supreme Court affirmed Defendant’s conviction for one count of conspiracy to deliver a controlled substance, methamphetamine, thus rejecting Defendant’s claims of error on appeal. Specifically, the court held (1) the trial court did not abuse its discretion or commit plain error in admitting certain testimony into evidence; (2) the trial court did not err in denying Defendant’s motion to dismiss on Fifth Amendment double jeopardy grounds; and (3) plain error did not occur when a law enforcement witness offered his opinion that Defendant committed the crime of conspiracy to deliver methamphetamine. View "Garriott v. State" on Justia Law

The Supreme Court reversed Appellant’s conviction for aggravated assault entered after a jury trial. The district court sentence Appellant to life in prison. The Supreme Court held (1) the prosecutor’s failure to comply with the court’s discovery order constituted misconduct; (2) the district court abused its discretion in denying Appellant’s motion to restrict witness testimony; (3) the prosecutor committed misconduct during closing argument; (4) Appellant was denied due process of law because he was required to wear a leg brace in the presence of the jury; and (5) because of the cumulative effect of these errors, Appellant was denied a fair trial. View "Black v. State" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion requesting that the criminal case against him be dismissed based upon the Fifth Amendment’s prohibition against double jeopardy.A jury convicted Defendant of felonious restraint, strangulation of a household member, and domestic battery. Defendant’s first trial resulted in a mistrial at Defendant’s request after the district court concluded that the prosecutor asked Defendant improper questions during cross-examination. Before the second trial commenced, Defendant filed a motion to dismiss the charges against him based on the Fifth Amendment’s prohibition against double jeopardy. The district court denied the motion, explaining that there was no evidence that suggested the State had intentionally goaded Defendant into requesting a mistrial. Defendant was subsequently found guilty of felonious restraint, strangulation of a household member, and domestic battery. The Supreme Court affirmed, holding that the district court’s finding that the prosecutor did not goad Defendant into requesting a mistrial was not clearly erroneous. View "King v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions on one charge of domestic battery and one charge of strangulation of a household member. On appeal, Defendant argued that his convictions and sentences for both crimes violated his constitutional protections against double jeopardy because domestic battery is a lesser included offense of strangulation of a household member. The Supreme Court held that the district court did not commit plain error when it convicted and sentenced Defendant for the crimes of domestic battery and strangulation of a household member because Defendant’s two convictions arose from separate and distinct conduct, and therefore, Defendant failed to establish a double jeopardy violation. View "Drakeford v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions of three counts of sexual abuse of a minor in the second degree and one count of sexual abuse of a minor in the third degree for Defendant’s sexual abuse of the daughter of his girlfriend. Defendant appealed, arguing that his trial counsel provided ineffective assistance in multiple ways and that the district court committed reversible error. In affirming, the Supreme Court held (1) Defendant’s trial counsel was not ineffective in her representation of Defendant; and (2) there was no reversible error on the part of the district court. View "Woods v. State" on Justia Law