Justia Wyoming Supreme Court Opinion Summaries

Articles Posted in Civil Rights
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The Supreme Court affirmed Defendant's conviction of felony strangulation of a household member and misdemeanor false imprisonment, holding that the district court did not err or abuse its discretion in the proceedings below.On appeal, the Supreme Court held that the district court (1) did not err by concluding that the affidavit in support of the search warrant to search Defendant's cellular phones, his place of employment, his work truck, and his person for certain documents, including journals, established probable cause to search and seize Defendant's journals and in thus denying Defendant's motion to suppress; and (2) did not abuse its discretion at sentencing by considering conduct for which Defendant was acquitted. View "Kreusel v. State" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the district court convicting Defendant of second-degree murder after denying his motion to suppress, holding that the district court erred in determining when Defendant's interrogation became custodial, and that error required reversal.Specifically, the Supreme Court held (1) the district court erred in ruling that Defendant was not in custody during his police station interview until he was directed to remain in an interview room; (2) it was not harmless error to admit incriminating statements Defendant made after his interrogation became custodial; and (3) the record supported the district court's conclusion that Defendant's confession was voluntary. View "Mills v. State" on Justia Law

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The Supreme Court affirmed the order of the district court granting the petition filed by the Wyoming Department of Family Services (DFS) to terminate Father's parental rights, holding that Father was not entitled to relief on his claims of error on appeal.On appeal, Father argued that he received ineffective assistance of counsel during the termination proceedings and that the district court erred in denying his motion to set aside the entry of default. The Supreme Court disagreed and affirmed, holding (1) because Wyo. Stat. 14-2-318(a) does not create a mandatory right to counsel, it does not create a statutory right to effective assistance of counsel in termination of parental rights cases; and (2) the district court did not abuse its discretion in denying Father's motions to set aside the entry of default. View "Roberts v. State, Dep't of Family Services" on Justia Law

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The Supreme Court affirmed the judgment of the Division of Criminal Investigation (DCI) denying Applicant's application for a concealed firearm permit renewal, holding that DCI's denial of Applicant's concealed firearm permit application was not arbitrary, capricious, or otherwise not in accordance with the law.In denying Applicant's concealed firearm permit renewal application, DCI relied on recommendations and information from the Albany County Sheriff and City of Laramie Chief of Police, stating that it made its decision after "reach[ing] out to local law enforcement." The district court affirmed. The Supreme Court affirmed, holding (1) Applicant had a meaningful opportunity to rebut the evidence against him; and (2) DCI's decision was not arbitrary or capricious or otherwise not in accordance with the law. View "Lemus-Frausto v. State, ex rel. Division of Criminal Investigation" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of felony shoplifting after a jury trial, holding that the district court did not err or abuse its discretion.On appeal, Defendant argued that his right to a speedy trial was violated and that the district court abused its discretion by allowing a juror who inadvertently saw a video about the trial on social media to remain on the jury. The Supreme Court disagreed and affirmed, holding (1) Defendant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48 or the Sixth Amendment; and (2) Defendant waived any claim related to alleged juror impropriety by not objecting before the return of the verdict. View "Vlahos v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Appellant's motion filed under Wyo. R. App. P. 21 for a new trial based on ineffective assistance of counsel, holding that the district court did not err by denying the motion.After a jury trial, Defendant was convicted of aggravated burglary, aggravated assault and battery, and other crimes after repeatedly confronting his estranged wife and her male friend. On appeal, Defendant argued that the trial court erred in denying his motion for a new trial based on ineffective assistance of counsel. Specifically, Defendant alleged that trial counsel failed properly to advise him of his right to plead not guilty by reason of mental illness. The district court denied the motion, concluding that trial counsel's performance was not deficient. The Supreme Court affirmed, holding that Defendant did not meet his burden to show that prejudice resulted from trial counsel's alleged deficient performance. View "Buckingham v. State" on Justia Law

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The Supreme Court affirmed the order of the district court adjudicating JP delinquent and the corresponding order of disposition, holding that Defendant did not receive ineffective assistance of counsel when his attorney failed timely to demand a jury trial.The State filed a delinquency petition alleging that seventeen-year-old JP inflicted sexual intrusion on a thirteen-year-old girl. After a hearing, the juvenile court found that JP committed a delinquent act and sentenced him to one year of juvenile probation. On appeal, JP argued that he was prejudiced by his counsel's failure to timely demand a jury trial. The Supreme Court affirmed, holding that JP failed to show the outcome of his case would have been different if it had been tried to a jury. View "JP v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court sentencing Defendant to the maximum term of fifteen to twenty years for aggravated vehicular homicide and a concurrent six months for driving under the influence, holding that the district court plainly erred when it considered Defendant's silence and community expectations in sentencing her.On appeal, Defendant argued that her constitutional right to a fair sentence was violated when the district court "emphasized, and likely punished, her decision to exercise her constitutional rights at the time of her arrest" and when the court expressed that "the severity of the sentence depended upon the county in which it presided over her." The Supreme Court agreed and remanded the case for a new sentencing hearing, holding that the district court erroneously incorporated constitutionally-prohibited factors into its sentencing decision and that the application of those constitutionally-prohibited factors in sentencing undermined the fairness and integrity of the judicial proceedings. View "Jewkes v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of attempted first-degree arson, entered after a jury trial, holding that the evidence was sufficient to support the conviction and that the district court did not commit plain error by allowing a police officer to testify that gasoline is an accelerant.On appeal, Defendant argued that the State presented insufficient evidence to support his attempted first-degree arson conviction and that a police officer improperly opined as an expert that a liquid he identified as gasoline found in Defendant's home was an accelerant despite not being qualified to testify as an expert under Wyo. R. Evid. 702. The Supreme Court affirmed, holding (1) sufficient evidence supported the conviction; and (2) as to his remaining assignment of error, Defendant failed to satisfy the second prong of plain error review. View "Esquibel v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of felony possession of marijuana, entered following Defendant's conditional guilty plea, holding that the initial traffic stop of Defendant in this case comported with the requirements of the Fourth Amendment to the United States Constitution.In denying Defendant's motion to suppress, the trial court concluded that the initial traffic stop was justified as a drug trafficking investigation. Defendant appealed, arguing that the district court erred in concluding the officer had reasonable suspicion to stop Defendant based on the collective knowledge doctrine. The Supreme Court affirmed, holding that the initial stop was legally justified under the Fourth Amendment, and therefore, the district court did not err in denying Defendant's motion to suppress. View "Guandong v. State" on Justia Law