Justia Wyoming Supreme Court Opinion Summaries

Appellant Mark Garner was convicted on two counts of delivery of a controlled substance after he was arrested for selling methamphetamine to a confidential informant in two controlled buy operations initiated by the Wyoming Division of Criminal Investigation. Garner appealed, contending (1) the district court improperly limited cross-examination of the confidential informant, a key prosecution witness; and (2) the evidence was insufficient to support his convictions. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in admonishing defense counsel, limiting his cross-examination, and issuing a limiting instruction to the jury when defense counsel was cross-examining the confidential informant; and (2) there was ample evidence to support Appellant's convictions. View "Garner v. State" on Justia Law

Marvin Tilley was convicted of six counts of sexual assault committed years previously against four different victims and one count of aggravated burglary against one of the victims. Tilley appealed, challenging the sufficiency of the evidence to convict him. At issue on appeal was the credibility of the witnesses and their memories. The Supreme Court affirmed, holding (1) the evidence was sufficient as to the date of the assaults and the fact that the victims did not consent to the sexual acts, (2) there was no basis to question the credibility determinations of the jury, and (3) therefore, the evidence was sufficient to support Tilley's convictions. View "Tilley v. State" on Justia Law

John Eckdahl was sentenced following his conviction of possession of a controlled substance with intent to deliver. Just over a year later, Eckdahl filed a motion to modify his sentence. The district court denied the motion as untimely pursuant to Wyo. R. Crim. P. 35(b), which allows a motion for sentence modification within one year after the sentence is imposed. Eckdahl did not appeal the denial of his motion but instead filed a petition for reconsideration, followed by another motion to reduce his sentence. The district court entered an order denying both the petition for reconsideration and the pending motion for sentence reduction. The Supreme Court dismissed Eckdahl's appeal, holding that it lacked jurisdiction because Eckdahl's motions for sentence reduction were untimely and Eckdahl's petitions for reconsideration were not authorized under Wyoming law. View "Eckdahl v. State" on Justia Law

In these consolidated appeals, Appellant Ryan Hagerman challenged the district court's denials of motions to correct illegal sentence that he filed in two unrelated, but temporally overlapping, cases. Appellant was first sentenced in a burglary case and later sentenced in a stolen property case. The Supreme Court remanded the burglary case for resentencing and affirmed the judgment of the district court in the stolen property case, holding (1) the sentence in the burglary case was illegal because Appellant's presentence confinement time was not properly credited against the sentence; and (2) the sentence in the stolen property case was not rendered illegal by the fact that Appellant was given credit against that sentence to which he was not entitled. View "Hagerman v. State" on Justia Law

Appellant Leah Benjamin was convicted of second-degree murder for the shooting death of her estranged husband. On appeal, the Supreme Court affirmed, holding (1) the trial court did not abuse its discretion by denying Appellant's request to remove a juror who was related to one of the State's listed witnesses; (2) the trial court did not err in refusing Appellant's proposed jury instructions; (3) the trial court did not err in denying Appellant's post-trial motion for judgment of acquittal; and (4) Appellant failed to demonstrate that the prosecutor engaged in prejudicial misconduct during the prosecutor's opening statement, voir dire, or the prosecutor's closing argument. View "Benjamin v. State" on Justia Law

Appellant Mark Orchard was arrested for driving while under the influence of alcohol. As a result, the Wyoming Department of Transportation (DOT) advised Appellant that it was suspending his driver's license. Appellant contested the suspension before the Office of Administrative Hearings (OAH), and the OAH upheld the suspension. The district court affirmed. Appellant appealed, contending that the police officer who arrested him lacked reasonable suspicion to initiate the traffic stop. The Supreme Court affirmed, holding that the DOT's certified record, which included the arresting officer's signed statement, constituted relevant evidence that a reasonable mind might accept as adequate to support the determination that the arrested office had probable cause or reasonable suspicion to initiate a traffic stop of Appellant's vehicle. View "Orchard v. State Dep't of Transp." on Justia Law

Appellant Joshua Lascano was convicted of one count of burglary and sentenced to six to ten years. During trial, in order to have evidence indicating that Lascano was a member of a gang admitted, the State asserted that the burglary was an act of gang retaliation and that, but for the gang affiliations, the burglary would not have occurred. Lascano appealed, arguing that the prosecutor committed misconduct by misrepresenting the relevance of the gang evidence. The Supreme Court affirmed, holding (1) no prosecutorial misconduct occurred when gang evidence was admitted in this case, and (2) the district court did not abuse its discretion in so admitting the gang evidence. View "Lascano v. State" on Justia Law

A state trooper stopped William Tiernan on suspicion of driving while impaired after he observed Tiernan's vehicle cross the center line and fog line a couple of times. The trooper conducted field sobriety tests and arrested Tiernan for driving under the influence of alcohol. Tiernan refused to submit to chemical testing. The Department of Transportation (DOT) subsequently suspended Tiernan's driver's license. The Office of Administrative Hearings (OAH) upheld the suspension. The district court affirmed. Tiernan appealed, contending that the trooper failed to present sufficient facts to support the stop for a lane violation. The Supreme Court affirmed, holding that substantial evidence supported the agency's decision. View "Tiernan v. State" on Justia Law

Appellant Randal Craft entered a conditional guilty plea to felony possession of a controlled substance and reserved the right to appeal whether he entered a valid waiver of counsel in a prior conviction that was used to enhance the present charge to a felony. The Supreme Court affirmed, holding that the district court did not err in finding Appellant's waiver of counsel in the proceeding at issue was knowing and intelligent where the advisements given in the proceeding complied with the requirements of Wyo. R. Crim. P. 11, and there was no indication in the record that Appellent did not understand those advisements, including the advisement that he had a right to an attorney. View "Craft v. State" on Justia Law

In 1999, James Graham was convicted on four counts of obtaining property by false pretenses. Graham's appeal challenged the amount of restitution ordered as part of his sentence. The Supreme Court affirmed in part and reversed in part. In 2010, Graham filed a motion to correct an illegal sentence. The district court ruled that Graham's sentence was not illegal and denied the motion. The Supreme Court affirmed, holding (1) Graham's appeal was barred under the doctrine of res judicata because he could have raised the majority of his issues in his initial appeal and did not suggest any good cause for failing to do so; (2) because res judicata barred his claims that the underlying sentence was illegal, there was no foundation for his challenge to the subsequent revocation of his probation; and (3) the Court was not compelled to consider Graham's claims in the interests of justice, largely because his claims were without merit. View "Graham v. State" on Justia Law