Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of larceny by bailee. The district court sentenced Appellant to eight to ten years in prison but suspended the sentence and placed him on probation. The court also ordered Appellant to pay restitution in the amount of $127,208. The Supreme Court affirmed, holding (1) because he failed to demonstrate prejudice by his counsel’s alleged errors, Appellant could not prevail on his claim that he was denied his right to effective assistance of counsel; and (2) the district court did not abuse its discretion in ordering Appellant to pay restitution in the amount of $127,208. View "Hibsman v. State" on Justia Law

Phillip Sam was charged as an adult with one count of first degree murder and twelve counts of aggravated assault. Sam was sixteen years old at the time of the offense, and several witnesses set to testify at trial were juveniles. After a hearing, the district court entered an order concerning media access during trial that limited the identification of juvenile witnesses who would testify during the trial in open court, concluding that this measure was necessary because some of the juvenile witnesses had been the subject of threats. Petitioner, a newspaper, challenged the prior restraint on publication imposed by the court. The Supreme Court reversed and vacated the district court’s order pertaining to the release of the names of juvenile witnesses, holding that the district court’s order violated the First Amendment because this was not the sort of exceptional case where the district court’s prior restraint on speech survives constitutional scrutiny. View "Cheyenne Newspapers, Inc. v. First Judicial Dist. Court" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree sexual abuse of a minor for sexually assaulting his teenage daughter. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting certain uncharged misconduct at trial; (2) Defendant’s trial counsel did not provide ineffective assistance by not uncovering certain evidence in time to be used at trial; and (3) Defendant’s due process rights were not violated when his appeal was delayed due to the court reporter’s untimely filing of the transcripts from the proceedings below. View "Hodge v. State" on Justia Law

Appellant suffered a workplace injury to his back and applied for permanent partial disability. The Workers’ Compensation Division denied benefits. Appellant requested a contested case hearing. During discovery, the Division served interrogatories and requests for production requesting information regarding Appellant’s work history since the time of his injury. Appellant objected to a number of the interrogatories and requests, asserting his Fifth Amendment right against self-incrimination. The hearing examiner compelled Appellant to answer the discovery, but Appellant continued to invoke his Fifth Amendment right against self-incrimination. The hearing examiner dismissed the contested case as a discovery sanction. The district court affirmed. The Supreme Court reversed, holding (1) Appellant was justified in asserting his Fifth Amendment privilege against self-incrimination because he reasonably believed his answers to the discovery requests could be used in a criminal prosecution against him; and (2) the hearing examiner abused his discretion by acting arbitrarily and capriciously in dismissing the case as a discovery sanction without engaging in the proper balancing of Appellant’s and the Division’s conflicting interests. View "Debyah v. State, ex rel., Dep’t of Workforce Servs." on Justia Law

After a jury trial, Defendant was convicted for aiding and abetting aggravated robbery. Defendant appealed, asserting that the district court denied him the right to due process when it refused to instruct the jury on his defense of duress. The Supreme Court reversed and remanded for a new trial, holding that the district court denied Defendant of his right to a fair trial when it ruled that the duress defense instruction would not be given to the jury after Defendant testified and admitted the elements of the crime, as the facts of the case were sufficient to establish a jury question as to Defendant’s duress defense. View "James v. State" on Justia Law

After a jury trial, Defendant was found guilty of felony theft. The Supreme Court affirmed, holding (1) there was sufficient evidence for the jury to reasonably conclude that Defendant possessed the requisite intent to deprive; (2) the district court did not abuse its discretion when it imposed no sanction for the State’s discovery violation; (3) the district court erred when when it allowed evidence of Defendant’s prior felony conviction, but the error was harmless; (4) the district court did not commit plain error when it prohibited defense counsel from questioning a police officer about Defendant’s “nonstatements” made during his interview following his arrest; and (5) Defendant waived his right to challenge the district court’s response to the jury question under the invited error doctrine. View "Toth v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree sexual abuse of a minor and one count of second-degree sexual abuse of a minor. The Supreme Court affirmed, holding (1) the district court did not err in admitting evidence of Appellant’s prior conviction for sexual assault; (2) the district court did not err in excluding evidence of the victim’s prior sexual conduct; (3) the district court did not err in admitting evidence of domestic abuse; and (4) the prosecutor did not commit misconduct in his statements made during closing argument. View "Carroll v. State" on Justia Law

After a jury trial, Defendant was convicted of aiding and abetting aggravated robbery. Defendant appealed, arguing that the district court denied him the right to due process by declining to instruct the jury on his defense of duress. The Supreme Court reversed and remanded for a new trial, holding that Defendant was denied his right to a fair trial when the district court refused to instruct the jury on Defendant’s defense of duress after Defendant testified and admitted the elements of the crime. Given the evidence presented in this case, Defendant was entitled to a jury determination as to whether he had a reasonable opportunity to avoid the crime. View "James v. State" on Justia Law

In this child neglect proceeding, the juvenile court found that it was in the child’s best interest to cease efforts to reunify him with Mother and to change the permanency plan to termination of parental rights and eventually adoption. The Supreme Court affirmed the juvenile court’s order, holding (1) while due process may require an evidentiary hearing when a permanency plan is changed from family reunification to termination of parental rights, Mother failed to establish plain error in the juvenile court’s failure to apply the Wyoming Rules of Evidence during the permanency hearing; and (2) sufficient evidence supported the juvenile court’s finding that to find that it was in the child’s best interests to change the permanency plan to adoption. View "In re GC" on Justia Law

After a jury trial, Defendant was found guilty of three counts of delivery of cocaine. The Supreme Court reversed the conviction and remanded for a new trial, holding (1) the evidence was sufficient to support the conviction; (2) Defendant was not denied his right to confrontation when law enforcement officers testified about results of tests conducted by others; (3) the prosecutor did not commit misconduct; but (4) Defendant’s trial counsel rendered ineffective assistance by failing to object to improper testimony and argument, by failing to demand notice of Wyo. R. Crim. P. 404(b) evidence and enter an objection to the testimony, and by failing to request that audio tapes of controlled buys be played in their entirety, and Defendant was prejudiced by counsel’s deficient performance. View "Fennell v. State" on Justia Law