Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of one count of aggravated cruelty to animals, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant abandoned his argument that the district court erred when it allowed his wife to invoke spousal privilege in the presence of the jury; (2) the district court did not abuse its discretion when it admitted testimony and evidence from a witness who was not disclosed pretrial; (3) Defendant was not prejudiced by prosecutorial misconduct; and (4) Defendant failed to satisfy the plain error test as to his argument that the district court violated his right against self-incrimination under the Federal and Wyoming Constitutions when it ordered him to participate in the preparation of a presentence investigation as a condition of his bond. View "Berry v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellants' joint motion to suppress more than 300 pounds of marijuana law enforcement discovered during a traffic stop on Interstate 80 in Wyoming, holding that the district court did not err when it denied Appellants' motion to suppress evidence.Appellants - Cristian Ramirez and Hector Zapien-Galvan - were pulled over by state troopers for an expired registration. Appellants refused to consent to a search of the car, after which a certified canine alerted to packages containing 320.6 pounds of marijuana. Appellants moved to suppress the evidence, arguing that the officer's conduct in pursuing their vehicle without reasonable suspicion negated the subsequent probable cause for the search. The district court denied the motion. The Supreme Court affirmed, holding that the district court properly denied Appellants' motion to suppress because the underlying traffic stop was both objectively justified and reasonable at its inception and did not violate Wyo. Const. art. I, 4 or the Fourth Amendment. View "Zapien-Galvan v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to withdraw his pleas of no contest to voluntary manslaughter, attempted voluntary manslaughter, two counts of aggravated robbery, and four counts of interference with a peace officer, holding that the district court did not abuse its discretion when it denied Defendant's motion to withdraw his no contest pleas.Defendant pleaded no contest to the charges against him pursuant to a plea agreement with the State. Before he was sentenced, Defendant moved to withdraw his pleas, arguing that his right to a speedy trial was violated and that defense counsel did not provide effective assistance of counsel. The district court denied the motion and sentenced Defendant according to the plea agreement. That Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant's motion to withdraw his pleas. View "McHenry v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant, following a jury trial, of two counts of second-degree sexual abuse of a minor, holding that the prosecutor did not commit prosecutorial misconduct in the underlying proceedings.On appeal, Defendant argued that the prosecutor committed misconduct in the way he referred to and used the testimony of a forensic interviewer in his opening statement and closing argument. The Supreme Court disagreed and affirmed, holding (1) Defendant failed to establish that the prosecutor's statement violated a clear and unequivocal rule of law; and (2) there was no plain error in the State's closing argument. View "State v. Ward" on Justia Law

The Supreme Court affirmed the judgments of the district courts denying Appellants' separate motions to suppress, holding that the Wyoming Constitution does not require that an exterior canine sniff of a vehicle be supported by probable cause.Appellants in these cases were both subjected to an extended investigative detention, and both Appellants were arrested after a canine sniff of their vehicles. On appeal, Appellants argued that the canine sniffs had to be supported by probable cause under Wyo. Const. art. I, 4. The Supreme Court disagreed, holding (1) the Wyoming Constitution does not require probable cause for an exterior canine sniff of a vehicle; and (2) Appellants were not entitled to relief on their remaining allegations of error. View "Tarzia v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's claims against Defendant, the mayor of Green River, as time-barred, barred under 42 U.S.C. 1983, and barred by the doctrine of collateral estoppel, holding that the district court did not err.In his complaint, Plaintiff alleged that Defendant violated his oath of office during Plaintiff's underlying criminal matter by declining to order an investigation into a witness who recanted prior statements she made to law enforcement. The district court dismissed the complaint. The Supreme Court affirmed, holding (1) the district court did not err when it determined that Plaintiff's claims were barred by the Wyoming Governmental Claims Act and 42 U.S.C. 1983; (2) Plaintiff failed to present cogent argument on his collateral estoppel argument; and (3) therefore, the district court properly granted Defendant's motion to dismiss. View "Mitchell v. Rust" on Justia Law

The Supreme Court reversed the judgment of the district court ruling that a bylaw adopted by the Uinta County Republican Party governed who could vote in its 2021 officer and state committee-person election, holding that the voting procedure used in the election and the Party's bylaw violated the clear and unambiguous language of Wyo. Stat. Ann. 22-4-105.In making its decision, the district court ruled that the bylaw did not violate the relevant provision of the Wyoming Election Code, Wyo. Stat. Ann. 22-4-105, and that the Party's constitutional right to freedom of association would be unduly burdened if it was prohibited from adopting and utilizing the bylaw. The Supreme Court reversed, holding (1) the district court erred in concluding that the Party acted within its statutory authority by enacting the bylaw and using it for the 2021 election; and (2) the issue of whether section 22-4-15 infringed on the Party's constitutional right to freedom of political association was not properly before the Court. View "Conrad v. Uinta County Republican Party" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony possession of methamphetamine, holding that the district court did not err in denying Defendant's multiple motions to suppress challenging the validity of the warrant and supporting affidavit police obtained to search his residence.On appeal, Defendant argued that Officer Andy Lucas of the Gillette Police Department knowingly, or with reckless disregard, omitted facts from the search warrant affidavit and that the warrant was not sufficiently particular to remain valid under the Fourth Amendment. The Supreme Court disagreed, holding (1) the district court did not clearly err in finding Officer Lucas had not recklessly omitted information from the affidavit; and (2) the search warrant contained sufficient information to allow Officer Lucas to identify the place to be searched with reasonable effort. View "Herdt v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained after law enforcement forced open a lacked box during an inventory search of Defendant's vehicle, holding that the district court did not err.During an inventory search of Defendant's vehicle, the police forced open a locked box and discovered suspected illegal drugs. The State charged Defendant with felony possession of methamphetamine and misdemeanor possession of heroin. Defendant moved to suppress the evidence obtained from the box, arguing that opening the box exceeded the scope of a permissible inventory search in violation of the Wyoming Highway Patrol's (WHP) inventory policy, thus violating his Fourth Amendment rights. The district court denied the motion, after which Defendant entered a conditional plea of guilty to felony possession of methamphetamine. The Supreme Court affirmed, holding that Defendant's argument that the inventory search violated WHP policy was unavailing. View "Beckwith v. State" on Justia Law

The Supreme Court reversed Defendant's conviction for misdemeanor interference with a peace officer stemming from his act of resisting when police officers entered his home without a warrant to arrest him for a misdemeanor crime, holding that, under the circumstances of this case, Defendant's conviction could not stand.On appeal, Defendant argued that the officers' warrantless entry into his home was unlawful, and therefore, the trial court erred in denying his motion to suppress. The Supreme Court reversed, holding (1) the officers in this case were not "engaged in the lawful performance" of their official duties when they entered Defendant's home without a warrant, as required to convict him under Wyo. Stat. Ann. 6-5-204(a); and (2) because the officers' warrantless entry into Defendant's home was per se unreasonable, the warrantless entry into Defendant's home to execute a warrantless arrest violated Defendant's rights under the Fourth Amendment. View "Woods v. State" on Justia Law