Justia Wyoming Supreme Court Opinion Summaries

Defendant pled guilty to two counts of first degree murder and one count of larceny. Defendant was eighteen years old when he committed the crimes. At that time, the age of majority in Wyoming was nineteen. Defendant was sentenced to two consecutive sentences of life imprisonment on the murder counts. Defendant later filed a pro se motion to correct an illegal sentence under Wyo. R. Crim. P. 35, arguing that his life sentences violated the constitutional prohibition of cruel and unusual punishment. The Supreme Court affirmed, holding that Defendant’s sentence did not violate state law because the Eighth Amendment sentencing protections announced in Miller v. Alabama extend only to offenders under the age of eighteen. View "Nicodemus v. State" on Justia Law

Appellant was convicted of first-degree felony murder, aggravated burglary, and conspiracy to commit aggravated burglary. After the United States Supreme Court’s decision in Miller v. Alabama and the Supreme Court’s decision in Bear Cloud v. State, the Supreme Court vacated Appellant’s sentences for resentencing on all counts. Upon resentencing, the court sentenced Appellant to an aggregate sentence will require him to serve at least thirty-five years before he becomes parole eligible. Appellant appealed, arguing that his aggregate sentence violates constitutional protections against cruel and unusual punishment. The Supreme Court affirmed, holding (1) Appellant’s aggregate sentence is not a de facto sentence of life without the possibility of parole and does not violate the Eighth Amendment; and (2) Appellant’s aggravated burglary sentence of ten to twenty-five years is not grossly disproportionate or unconstitutional. View "Sen v. State" on Justia Law

Defendant entered a conditional guilty plea to felony possession of methamphetamine. Defendant reserved the right to challenge the denial of his motion to suppress the warrantless pat-down search of his person. On appeal, Defendant argued that the pat-down search amounted to an illegal warrantless search because there were no exigent circumstances to necessitate such a search. The Supreme Court affirmed the denial of Defendant’s motion to suppress, holding that the district court did not err in concluding that, based upon the totality of the circumstances, law enforcement was justified in conducting a warrantless pat-down search for officer safety reasons. View "Sweets v. State" on Justia Law

After Crook County Weed and Pest Control District applied herbicides to control leafy spurge found on property owned by Bush Land Development Company and Victoria Bush (collectively, Bush), many trees in the area of the spraying died. Bush filed this inverse condemnation action in the district court alleging that it was entitled to just compensation for the loss of its trees as a result of the District’s improper application of herbicides. The district court dismissed Bush’s claim, concluding that the action was not proper under the inverse condemnation statute. The Supreme Court affirmed on other grounds, concluding that the inverse condemnation was not properly before the district court because Bush failed to exhaust its administrative remedies before claiming inverse condemnation. View "Bush Land Development Co. v. Crook County Weed & Pest Control District" on Justia Law

Defendant entered a conditional no contest plea to possession of methamphetamine with the intent to distribute. Defendant appealed, arguing that the district court erred in denying his motion to suppress and finding that Defendant consented to continued detention when law enforcement told him “he was free to leave” but continued to have [its] red and blue emergency overhead lights activated. The Supreme Court affirmed, holding that, under the totality of the circumstances in this case, a reasonable person in Defendant’s position would have felt free to decline the law enforcement officer’s request, and therefore, the contact between the officer and Defendant was consensual. View "Tibbetts v. State" on Justia Law

Defendant was charged with felony stalking. Defendant’s first jury trial ended in a mistrial. Thereafter, a second jury found Defendant guilty of felony stalking. Defendant was sentenced to a term of incarceration, suspended on the condition that Defendant complete five years of probation. Defendant appealed, arguing that his rights against double jeopardy were violated because the prosecutor forced him into moving for a mistrial. The Supreme Court affirmed, holding (1) there was no evidence in the record indicating prosecutorial intent to provoke the defense into moving for a mistrial; and (2) therefore, Defendant’s rights against double jeopardy were not violated in this case. View "Montoya v. State" on Justia Law

In anticipation of receiving the recommendations of a staffing and compensation study conducted by the City of Cheyenne’s contractor, the City created the Employee Investment Study Implementation Team (EIS Team). The EIS Team was created to consider alternative means of implementing those recommendation. Before the EIS Team met, the Wyoming Tribune-Eagle, a newspaper, filed a petition for a declaratory judgment that the EIS Team must conduct its meetings in public, as required by the Wyoming Public Meetings Act. The district court granted summary judgment for the City, concluding that the EIS Team was not an “agency” as defined by the Act, and therefore, the EIS Team was not subject to the Act’s open meetings requirements. The Supreme Court affirmed, holding that the EIS Team was not subject to the Act because, although it was a committee, it was not created pursuant to Wyoming constitution, statute, or ordinance. View "Cheyenne Newspapers, Inc. v. City of Cheyenne" on Justia Law

Nikki Jo Burtsfield died in a law enforcement shooting. The county coroner examined the body and prepared the verdict and case docket, listing the manner and cause of death. Appellant filed a public records request with the coroner seeking disclosure of the verdict and case docket. Dissatisfied with the documents he received in response to his request, Appellant filed a “Motion for Reasonable Response” with the district court, requesting that the court order the coroner to produce a case docket of “sufficient detail.” The district court dismissed the action pursuant to Wyo. R. Civ. P. 12(c). The Supreme Court affirmed, holding (1) Appellant was actually requesting relief in mandamus, and even though he did not follow the pleading requirements, the district court had jurisdiction over the action; and (2) on the merits, while the district court erred in denominating its decision as a dismissal under Rule 12(c) rather than a summary judgment, its decision was correct because the coroner did not have an absolute, clear and indisputable duty to provide the detailed information requested by Appellant. View "Williams v. Sundstrom" on Justia Law

Cheyenne Newspapers, Inc. (the Tribune-Eagle) submitted a public records request to Laramie County School District Number One (the School District) asking to inspect certain school board member email communications. The School District, in response, downloaded the emails to a compact disc and made the compact disc available to the Tribune-Eagle subject to a fee for the time the School District staff spent retrieving the records. Thereafter, the Tribune-Eagle filed a declaratory judgment action seeking a ruling that the Wyoming Public Records Act does not allow the School District to charge for access to electronic records when the request is for inspection of the records and not for a copy of the records. The district court concluded, as a matter of law, that the School District was entitled to the fees it charged the Tribune-Eagle for access to the requested emails. The Supreme Court affirmed, holding that Wyo. Stat. Ann. 16-4-202(d)(i) allows a public record custodian to charge for inspection of an electronic record if the inspect request requires production of a copy of the record, and reasonableness is the limitation on the costs that may be charged a public records applicant under the statute. View "Cheyenne Newspapers, Inc., v. Board of Trustees of Laramie County School District Number One" on Justia Law

After a jury trial, Appellant was convicted of conspiracy to deliver a controlled substance. The district court sentenced Appellant to not less than four years nor more than eight years in prison. Appellant appealed, claiming that he received ineffective assistance of counsel because “a skilled criminal defense advocate would likely be able to secure a more favorable agreement than was obtained in his current sentence.” The Supreme Court affirmed, holding that Appellant failed to establish that he was prejudiced by counsel’s alleged deficient performance, and therefore, it was unnecessary to address the deficiency prong of the ineffectiveness standard. View "McNaughton v. State" on Justia Law