Justia Wyoming Supreme Court Opinion Summaries

Appellant, the manager of the Dubois branch of the Fremont County Library System (FCLS), used an FCLS account to order books for the Dubois school system. The FCLS executive director terminated Appellant, determining that Appellant had improperly used FCLS funds to purchase books for the District. The FCLS Board of Trustees upheld the termination based upon an erroneous belief that Appellant had violated Wyo. Stat. Ann. 9-13-105. The district court affirmed, concluding that the Board misread section 9-13-105 but that because Appellant’s employment was at-will, Appellant’s employment may be terminated at any time with or without cause. The Supreme Court affirmed, holding that, as an at-will employee, Appellant did not have a property interest in continued employment or a right to a contested case hearing. View "Sabatka v. Bd. of Trs. of the Fremont County Pub. Library Sys." on Justia Law

At approximately 10:18 p.m., police officers searched Defendant’s home pursuant to a search warrant and found marijuana and drug paraphernalia. Defendant was subsequently arrested and charged with delivery of and possession with intent to deliver a controlled substance. Defendant filed a motion to suppress the evidence seized in the search, arguing that the search was unlawful and in violation of his constitutional rights because the search warrant was served after 10 p.m. contrary to the plain language of the warrant. The district court granted the motion to suppress based upon a procedural violation of Wyo. R. Crim. P. 41(c). The Supreme Court reversed, holding that although the officers violated Rule 41(c), the violation did not warrant suppression of the evidence seized in the search under the circumstances of this case. View "State v. Deen" on Justia Law

After a jury trial, Appellant was convicted of one count of attempted second-degree sexual abuse of a minor. The Supreme Court affirmed, holding (1) the district court did not err by not declaring a mistrial after one potential juror made an improper remark and others who were ultimately excused became emotional during voir dire; (2) the district court did not abuse its discretion by supplementing the jury instructions consistent with the Information to clarify the conduct charged; and (3) the delay between Appellant’s conviction and sentencing did not violate his constitutional right to speedy sentencing. View "Brown v. State" on Justia Law

Pursuant to a plea agreement, Defendant pleaded no contest to second degree sexual abuse. Defendant was previously convicted of a similar offense and specifically acknowledged in the plea agreement that the sentence for a second conviction of second degree sexual abuse of a minor was life in prison without the possibility of parole. The district court sentenced Defendant to life in prison without the possibility of parole. The Supreme Court affirmed, holding (1) Defendant’s sentence of life without the possibility of parole did not violate the Eighth Amendment because it was not grossly disproportionate to the crime; and (2) the sentence did not violate Wyo. Const. art. I, 14. View "Norgaard v. State" on Justia Law

Appellant was charged with four drug-related felonies. Appellant filed a motion and an amended motion to suppress the evidence police officers obtained against him in a search of Appellant’s apartment. The district court denied the motion, and Appellant entered a conditional guilty plea to felony possession of marijuana. Appellant appealed, challenging the denial of his motion to suppress. The Supreme Court reversed, holding that the district court (1) erred in concluding that the initial intrusion into Appellant’s apartment was lawful and justified by the emergency assistance exception to the Fourth Amendment’s warrant requirement; and (2) correctly found that Appellant’s consent to the police’s later entry into and search of his apartment was voluntarily given. Remanded for a ruling on whether Appellant’s consent was tainted by the initial unlawful search of his apartment. View "Campbell v. State" on Justia Law

In 2011, after a jury trial, Defendant was convicted of aggravated burglary and kidnapping and found to be a habitual criminal. The district court sentenced Defendant to two concurrent life sentences. The Supreme Court affirmed the convictions and sentences. In 2013, Defendant filed a motion to correct an illegal sentence, arguing that one of the convictions the district court relied upon for the habitual criminal determination and the life sentences occurred when he was only sixteen years old and that consideration of that offense to impose a life sentence was unconstitutional under Miller v. Alabama. The district court denied Defendant’s motion to correct an illegal sentence. The Supreme Court affirmed, holding that the sentencing scheme at issue here did not mandate a life sentence for a juvenile, and therefore, Miller did not apply. View "Counts v. State" on Justia Law

Pursuant to a plea agreement, Appellant pled guilty to two misdemeanor counts of sexual battery. The district court sentenced Appellant to the maximum penalty of two consecutive one-year terms of incarceration with a portion of his sentence suspended in favor of probation. The State later filed a petition to revoke Appellant’s probation for violating the conditions of his probation. Appellant elected to represent himself during the revocation proceedings. The district court found that Appellant had violated his probation and imposed the suspended jail sentence. Appellant appealed, asserting that the district court failed to properly advise him about the dangers of representing himself in the revocation proceedings, and therefore, his decision to forego counsel was not knowing and intelligent. The Supreme Court affirmed, holding that although the advisements given by the district court did not satisfy Faretta v. California and its progeny, Appellant’s waiver of his right to counsel was knowing and intelligent. View "Reifer v. State" on Justia Law

Appellant, an inmate serving a sentence of life imprisonment, filed a 42 U.S.C. 1983 civil rights action against Appellees, three employees of the Wyoming Department of Corrections, alleging that Appellees violated his federal constitutional right to due process by placing his earnings in a mandatory savings account from which he could not withdraw without a hearing. The district court dismissed the complaint. Appellant did not appeal the order dismissing his case but, instead, filed a motion for relief from the order of dismissal under Wyo. R. Civ. P. 60(b)(5) and (6). The district court denied the rule 60(b) motion. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the motion and that Appellant failed to show that his failure to receive Appellees’ response to his motion deprived him of due process. View "Nicodemus v. Lampert" on Justia Law

After a jury trial, Appellant was convicted of four counts of sexual abuse of a minor in the second degree and was sentenced to thirteen to fifteen years on each count, to be served consecutively. The Supreme Court affirmed on appeal. Appellant subsequently filed a pro se motion for sentence reduction pursuant to Wyo. R. Crim. P. 35(b) requesting that the district court merge his sentences on the grounds that all of the charges stemmed from the same offense and therefore violated the prohibition against double jeopardy. The district court denied the motion. The Supreme Court affirmed, holding that Appellant’s claim was barred by res judicata because he failed to present his double jeopardy claim in his initial appeal. View "Leonard v. State" on Justia Law

Defendant was a juvenile when he was convicted in 1995 of felony murder and sentenced to life in prison, a sentence that was by operation of law the equivalent of life imprisonment without the possibility of parole. In 2013, Defendant filed a motion to correct an illegal sentence, arguing that his sentence of life without the possibility of parole was unconstitutional under Miller v. Alabama. The district court certified two questions to the Supreme Court regarding the retroactivity of Miller. The Supreme Court held (1) the proper rule for determining whether a new constitutional rule applies retroactively to cases on collateral review is the test announced by the U.S. Supreme Court in Teague v. Lane; (2) under a Teague analysis, the rule announced in Miller applies retroactively to cases on collateral review; and (3) by operation of the amended parole statutes, the current sentence Defendant was serving was life with the possibility of parole after twenty-five years of incarceration. View "State v. Mares" on Justia Law