Justia Wyoming Supreme Court Opinion Summaries

Appellant Christopher Harrell was convicted of rape, kidnapping, and assault. Appellant appealed, arguing that the district court abused its discretion when it did not allow him to introduce evidence that he had been acquitted of a previous battery charge and that his Sixth Amendment right to compulsory process was violated because he was deprived of testimony that was vital, material, and relevant to his defense. The Supreme Court affirmed, holding that Appellant's arguments were not persuasive and that Appellant did not demonstrate that he suffered prejudice from the district court's refusal to allow him to introduce testimony about his previous acquittal for battery. View "Harrell v. State" on Justia Law

Petitioner Bobby Jenkins was charged with misdemeanor animal cruelty after a horse he owned was discovered in dire physical condition. A jury convicted him of the charges. The district court affirmed. Petitioner petitioned the Supreme Court for a writ of review, alleging ineffective assistance of counsel. The Supreme Court affirmed, holding that Petitioner failed to show that he was materially prejudiced by trial counsel's failure to (1) object to testimony and argument regarding the arrest and incarceration of both Petitioner and his brother, (2) object to the prosecutor's improper questioning of a witness about the credibility of another witness, or (3) object to the prosecutor's question relating to allegedly irrelevant testimony about the condition of other horses and Petitioner's speeding ticket. View "Jenkins v. State" on Justia Law

Appellant Thomas Stastny was convicted of sexual abuse of a minor and attempted sexual abuse of a minor. On appeal, Appellant challenged the district court's admission of evidence of a prior conviction, accused the prosecutor of committing misconduct during closing argument, and alleged that these cumulative errors required reversal of his convictions. The Supreme Court affirmed, holding (1) the doctrine of invited error barred Appellant from raising in his appeal issues concerning the admission of evidence of his prior conviction, (2) plain error did not occur as a result of prosecutorial misconduct during closing argument, and (3) as there was no error, the doctrine of cumulative error did not require reversal of Appellant's convictions. View "Stastny v. State" on Justia Law

Craig Winstead pled guilty to three counts of third degree sexual assault, and the district court sentenced him to ten to fifteen years on each count with the sentence on the first count to be served first and the sentences on the second and third counts to be served consecutively to the first sentence and concurrently with each other. Winstead filed a motion to correct on illegal sentence, claiming his sentences should have merged and asking the court to order that he serve his sentences concurrently. The district court denied the motion. The Supreme Court affirmed, holding that Winstead's claim was barred by the doctrine of res judicata because Winstead could have raised the issue during the sentencing hearing, on direct appeal, or when he filed a motion for judgment and sentence nunc pro tunc and failed to do so. View "Winstead v. State" on Justia Law

Appellant Dana Dickey entered a conditional plea to one count of possession of a controlled substance. Dickey reserved the right to appeal the district court's denial of her motion to suppress the methamphetamine found in her purse following a traffic stop, claiming the evidence should have been suppressed as the fruit of a constitutionally infirm detention under the Fourth Amendment. The Supreme Court affirmed, holding that the district court did not err by denying Dickey's motion to suppress where (1) the detention lasted no longer than necessary to effectuate the purpose of the stop, (2) the use of a drug dog during Dickey's lawful detention did not violate any constitutionally protected right, and (3) law enforcement officers had probable cause to search the vehicle. View "Dickey v. State" on Justia Law

Appellant Marshall Washington, while working as a confidential informant for the Division of Criminal Investigation (DCI), was charged with and found guilty of possession of a controlled substance. The district court's judgment and sentence incorrectly stated that Appellant pled guilty to the offenses, and the parties entered a stipulated motion to modify the judgment and sentence to correct the inaccuracy. Washington appealed, arguing that (1) the district court improperly denied discovery of the confidential informant agreement (CI agreement) between him and the DCI as well as the DCI's policy manual; and (2) the matter should be reversed inasmuch as the modified judgment and sentence did not fully comply with Wyo. R. Crim. P. 32. The Supreme Court affirmed the conviction, holding that no reversible error was committed by the trial court because (1) Appellant had access to the CI agreement prior to trial and referred to the document at trial, and denial of Appellant's motion to compel discovery of DCI's policy manual was not an abuse of discretion; and (2) the omissions in the modified judgment and sentence were simply clerical errors that would be corrected on remand to the district court. Remanded. View "Washington v. State" on Justia Law

David Baker was convicted on six methamphetamine-related charges. The Supreme Court reversed his convictions on two of the charges and affimed the other four. In these consolidated appeals, Baker (1) challenged the district court's denial of his motion to correct an illegal sentence, and (2) claimed the district court erred when it did not grant him access to e-mail correspondence between the department of corrections and the public defender's office. The Supreme Court affirmed the district court's decisions, holding (1) the district court did not abuse its discretion in denying Baker's motion to correct an illegal sentence, and (2) the district court was correct in observing that Baker's motion for subpoena duces tecum asking for the requested e-mail correspondence was not appropriate in the context of Baker's criminal matter. View "Baker v. State" on Justia Law

Appellant Warren Rathbun was convicted of attempted kidnapping and was sentenced to life in prison. On appeal, the Supreme Court affirmed the conviction and sentence, holding (1) Rathbun's prosecution for attempted kidnapping was not barred by the doctrine of double jeopardy due to his earlier guilty plea to battery because the two crimes each contained elements not contained in the other, and therefore, there was no preclusive effect; (2) the doctrine of res judicata neither barred the refiling of a charge for attempted kidnapping nor a subsequent preliminary hearing on the charge where there was a dismissal of the charge based upon a failure of proof of probable cause at a preliminary hearing; (3) the district court applied the proper penalty range in imposing sentence; and (4) the district court's determination of the penalty range in imposing sentence did not violate Rathbun's right to trial by jury. View "Rathbun v. State" on Justia Law

Christopher Jones pled guilty to a third battery against a household member and was sentenced to a prison term of four or five years. Jones appealed, contending that Wyo. Stat. Ann. 6-2-501(f)(ii), which prescribes the punishment for battery against a household member, was unconstitutionally vague. The Supreme Court affirmed, holding (1) Jones's argument that the statute was ambiguous did not constitute sufficient grounds to invalidate the statute as the mere fact that a statute is ambiguous is not sufficient in itself to violate the constitutional guarantee of due process; (2) the statute was not ambiguous; and (3) because the statute was unambiguous, the rule of lenity did not apply to the case. View "Jones v. State" on Justia Law

After a jury trial, Michael Downing was convicted of unlawful delivery of a controlled substance. Evidence was presented at trial involving an incident wherein a confidential informant (CI), who was working with the state Division of Criminal Investigation (DCI), arranged to purchase morphine pills from Downing. In his appeal, Downing alleged that the district court abused its discretion by denying his pretrial motion seeking discovery of "other buys" in which the CI participated and by excluding at trial evidence of other such buys. The Supreme Court reversed the judgment of conviction, holding that the district court's rulings excluding evidence of the CI's other buys (1) implicated Downing's Sixth Amendment right to confront a witness and (2) were not harmless error beyond a reasonable doubt. Remanded for a new trial. View "Downing v. State" on Justia Law