Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s convictions of two counts of aggravated assault and battery with a deadly weapon, one count of felony property destruction, and one count of attempted second degree murder. The court held (1) Defendant received a speedy trial as required by Wyo. R. Crim. P. 43 and the federal and state Constitutions; (2) the prosecutor did not commit misconduct during closing arguments; (3) Defendant received effective assistance of trial counsel; (4) the district court properly instructed the jury that it may infer malice from Defendant’s use of a deadly weapon; and (5) the district court did not violate Defendant’s constitutional protection against double jeopardy when it imposed separate sentences for aggravated assault and battery with a deadly weapon and attempted second degree murder. View "Webb v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction, rendered after a jury trial, of one count of domestic battery and one count of strangulation of a household member for attacking his girlfriend. On appeal, Defendant argued that the district court violated his constitutional right of confrontation when it refused testimony about the victim’s prior relationship from the sister of the victim’s former boyfriend. The Supreme Court disagreed, holding that the district court did not err by excluding the testimony under the rules of evidence and the court’s case law interpreting them. View "Garland v. State" on Justia Law

Defendant was sixteen years old when he committed the crimes at issue in this case. The Supreme Court affirmed Defendant’s convictions of one count of first-degree murder, one count of aggravated assault and battery, and ten counts of attempted aggravated assault and battery but reversed Defendant’s sentence and remanded for resentencing. The court held (1) the district court did not abuse its discretion when it denied Defendant’s motion to transfer the proceedings to juvenile court; (2) there were some errors in the jury instructions, but the errors were not prejudicial either individually or cumulatively; (3) the prosecutor’s victim impact statements during closing arguments were improper but not prejudicial; (4) there was sufficient evidence to support the attempted assault and battery charges; (5) Defendant’s aggregate sentence did not deprive the parole board of its statutory authority to consider parole of juveniles after twenty-five years; (6) Defendant’s sentence for murder and aggravated assault of the same victim did not violate double jeopardy; but (7) Defendant’s aggregate sentence violated the Eighth Amendment because it was a de facto life without parole sentence. View "Sam v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of first-degree felony murder but vacated Appellant’s sentence for the aggravated burglary conviction, the underlying felony. The court held (1) the district court did not err in refusing to instruct the jury that self-defense could be raised as a defense to a charge of felony murder; (2) the district court did not abuse its discretion in denying Appellant’s request to instruct the jury on the definition of the phrase “in the perpetration of” as used in Wyo. Stat. Ann. 6-2-101; but (3) the district court’s issuance of convictions for felony murder and aggravated burglary, the underlying felony, violated protections against double jeopardy. View "Schnitker v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of theft, rendered after a jury trial. On appeal, Defendant argued that the prosecutor committed misconduct when he mentioned Defendant’s race during rebuttal closing arguments. Specifically, Defendant argued that, in doing so, the prosecutor attempted to appeal to the racial bias of the jury. The Supreme Court held (1) when the prosecutor commented on Defendant’s race, he was doing so in response to defense counsel’s suggestion that race was an issue; and (2) therefore, there was no prosecutorial misconduct committed in this case and no plain error committed by the trial court. View "Cole v. State" on Justia Law

Bruce Williams submitted a public records request to the Campbell County Sheriff’s office requesting a list of the weapons or implements carried on persons of police officers involved in the killing of Niki Jo Burtsfield. After the Sheriff’s office responded, Williams made further inquiry, believing he was not provided all of the documents he requested. Thereafter, Williams filed a “petition for reasonable response” pursuant to Wyo. Stat. 16-4-202(b) and (c). The district court granted summary judgment for Scott Matheny, the Campbell County Sheriff. The Supreme Court affirmed, holding that because the Sheriff had, at the time of the district court’s ruling, provided the information that Williams requested, this inquiry was moot. View "Williams v. Matheny" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence collected pursuant to a search warrant, concluding that the police officer’s affidavit used to obtain the search warrant established probable cause sufficient to justify the issuance of the search warrant.Defendant entered a conditional guilty plea to charges of delivery of a controlled substance and possession of a controlled substance. On appeal, Defendant argued that the affidavit was deficient, that the circuit court improperly issued the warrant, and that the search violated Defendant’s rights under the Fourth Amendment to the United States Constitution and Wyo. Const. art. I, 4. The Supreme Court held that the affidavit established probable cause supporting the issuance of the search warrant. View "Fosen v. State" on Justia Law

A jury found Defendant guilty of one count of aggravated assault and battery after he hit Sam Trujillo with his vehicle. The trial court sentenced Defendant to two to four years in prison. The Supreme Court affirmed Defendant’s conviction, thus rejecting Defendant’s contention that his conviction should be reversed due to the ineffective assistance of counsel he received at trial. The court held that trial counsel was not ineffective in failing to request either an accident instruction or a defense of others jury instruction. View "Starr v. State" on Justia Law

Defendant was charged in the district court with criminal contempt for violating a juvenile court order. Defendant entered a conditional no contest plea to the criminal contempt charges. Defendant then timely appealed, raising several issues. The Supreme Court reversed, holding (1) Defendant’s entire plea was invalid, but the Court exercised its discretion to convert Defendant’s appeal to a writ of review in order to clarify some of the questions of law; (2) the district court had concurrent jurisdiction over this criminal contempt action arising from conduct in juvenile court; but (3) Defendant was denied due process because the order to show cause did not contain all the elements of the charged offense, an error that was compounded when Defendant’s attorney was denied access to the juvenile court file which contained the order Defendant was accused of violating. Remanded. View "Brown v. State" on Justia Law

Defendant was convicted of second-degree sexual assault of a minor. The district court sentenced Defendant to imprisonment for six to ten years. Defendant moved for a new trial on the ground that his trial attorney was ineffective. The district court denied the motion after an evidentiary hearing. The Supreme Court affirmed the conviction and sentence, holding (1) Defendant’s attorney provided constitutionally effective assistance; and (2) the evidence was sufficient to allow rational jurors to reasonably conclude beyond a reasonable doubt that Defendant caused the victim to touch him for sexual arousal or gratification. View "Jones v. State" on Justia Law