Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of one count of first degree sexual abuse of a minor, holding that the district court did not err in allowing the State to withdraw from its plea agreement with Defendant and that Defendant was not denied the right to testify in his own defense.Pursuant to a plea agreement, Defendant agreed to plead no contest to third degree sexual abuse of a minor. The State subsequently filed a motion to withdraw from the plea agreement. After a hearing, the district court granted the motion. After a jury trial, Defendant was found guilty of first degree sexual abuse of a minor. The Supreme Court affirmed, holding (1) because the State withdraw from its plea agreement before Defendant acted on his promise to change his plea and Defendant did not otherwise assert that he detrimentally relied on the agreement before the State withdraw from it, the agreement wasn't to an enforceable contract, and the district court did not err in granting the State's motion to withdraw from it; and (2) Defendant did not assert a cognizable claim that his right to testify was denied. View "Nelson v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for murder in the first degree and attempted murder in the first degree, holding that Defendant was not denied his right to a speedy trial or his right to a fair trial due to ineffective assistance of counsel or prosecutorial misconduct.Specifically, the Supreme Court held (1) Defendant was not denied his statutory or constitutional right to a speedy trial; (2) Defendant failed to establish that he was denied his constitutional right to effective assistance of counsel; and (3) Defendant failed to establish that he was denied his constitutional right to due process of law or a fair trial due to prosecutorial misconduct. View "Fairbourn v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions on three counts of second-degree attempted murder, thirteen counts of aggravated assault and battery, and one count of interference with a peace officer, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the district court’s finding of no discriminatory purpose in the State’s exercise of peremptory challenges was not clearly erroneous; (2) Defendant's right to a fair trial was not violated when the district court refused to individually query jurors about their exposure to pretrial publicity; (3) the district court did not abuse its discretion when it denied Defendant’s pretrial motion for a continuance; (4) the district court did not err in denying Defendant's motion for judgment of acquittal; (5) Defendant did not receive ineffective assistance of counsel; and (6) because there was no error, cumulative error did not deprive Defendant of a fair trial. View "Pickering v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of possession with intent to deliver a controlled substance, holding that the district court did not err in denying Defendant's motion to suppress.Defendant parked his car in a parking lot and was on his way into a bar when Officer Andy Lucus approached him and asked if they could talk. Defendant agreed. While they were talking, two other officers arrived at the scene. Officer Lucus asked if Defendant had proof of insurance. When Defendant could not locate his proof of insurance Officer Lucus wrote a "no insurance" citation. In the meantime, the other officers retrieved a K-9 named Lord to perform a free-air sniff of Defendant's vehicle. After Lord alerted to the smell of drugs Officer Lucus searched the vehicle and found methaphetamine. On appeal, Defendant conceded that his encounter with Officer Lucus began as consensual but asserted that the encounter changed to an unlawful investigatory detention when Officer Lucus requested proof of insurance. The Supreme Court affirmed without deciding the issue, holding that Lord's free-air sniff was lawful whether Defendant was free to leave or not. View "Kern v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence seized from his home, holding that the district court did not err when it concluded that the warrantless search of Defendant's home was constitutional under the emergency aid exception to the Fourth Amendment's warrant requirement.After the district court denied his suppression motion, Defendant entered a conditional guilty plea to various drug crimes, including possession of marijuana with intent to deliver, possession of methamphetamine, and possession of marijuana. Defendant appealed the denial of his motion to suppress. The Supreme Court affirmed, holding that intrusion into Defendant's home was lawful and justified by the emergency aid exception to the Fourth Amendment's warrant requirement. View "Ferch v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of two counts of sexual intrusion on a victim under Wyo. Stat. Ann. 6-2-314(a)(i), holding that the district court did not err when it admitted testimony under Wyo. R. Evid. 404(b) and 801(d)(1)(B) and did not violate Defendant's rights under the Confrontation Clause when it allowed the State to amend the felony information after the State had presented its witnesses.Specifically, the Supreme Court held (1) the district court did not abuse its discretion in admitting evidence of other acts under Rule 404(b) or in allowing the victim's prior consistent statements under Rule 801(d)(1)(B); and (2) the amendment to the felony information without a continuance did not deny Defendant his right to effectively cross-examine the witnesses or prejudice his defense. View "LaJeunesse v. State" on Justia Law

The Supreme Court reversed the judgment of the district court forfeiting $470,040 in United States currency seized from Robert Miller to the State under the Wyoming Controlled Substances Act, Wyo. Stat. Ann. 35-7-1001 to -1060, holding that the State unreasonably delayed filing the action.Miller filed a motion to dismiss the case on grounds that the State's 270-day delay in instituting proceedings violated the statutory requirement that the State institute such proceedings "promptly" and his due process rights under the United States Constitution. The district court denied the motion and forfeited the currency to the State. The Supreme Court applied the four-factor balancing test from Barker v. Wingo, 407 U.S. 514 (1972), to assess whether Miller's right to due process had been violated. The Court then reversed and remanded for dismissal with prejudice, holding that the State failed "promptly" to institute the forfeiture proceedings, in violation of section 35-7-1049(c) and Miller's right to due process under the federal Constitution. View "Miller v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Appellant's declaratory judgment action arguing that the Office of Administrative Hearings (OAH), and therefore the district court on appeal, did not have jurisdiction to decide his claim that a policy officer violated his due process right to an independent blood test, holding that the district court did not abuse its discretion in dismissing the declaratory judgment action.A police officer arrested Appellant for driving under the influence of alcohol. After an officer performed a chemical breath test, Appellant was issued a suspension order for his driver's license. Appellant requested a contested case hearing, arguing that the officer denied him the statutory ability to obtain a blood test at his own expense. The OAH upheld the suspension order, finding that the officer did not deprive Appellant of his right to an independent blood test. Appellant appealed and filed a separate declaratory judgment action seeking a declaration that law enforcement violated his statutory and substantive due process rights to independent testing. The district court dismissed the declaratory judgment action. The Supreme Court affirmed, holding (1) the OAH had jurisdiction over Appellant's administrative proceeding; and (2) the district court did not abuse its discretion in dismissing the declaratory judgment action. View "Johnson v. State ex rel., Wyoming Department of Transportation" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of two counts of possession with intent to deliver a controlled substance and one count of interference with a peace officer, holding that Defendant's trial counsel provided ineffective assistance by failing to challenge the extension of Defendant's traffic stop.The traffic stop in this case led to the discovery of drugs and drug paraphernalia in Defendant's vehicle. Defendant filed a motion to suppress, arguing that the initial stop was not supported by reasonable suspicion. The district court denied the motion. On appeal, Defendant argued, among other things, that his trial counsel provided ineffective assistance by failing to challenge the duration of the traffic stop in his motion to suppress. The Supreme Court reversed and remanded the case, holding (1) Wyo. R. Crim. P. 12(b) precluded plain error review of the issues not raised in Defendant's motion to suppress evidence; and (2) Defendant showed a reasonable probability that, but for counsel's failure to challenge the duration of the stop and the actions of law enforcement officers during the stop, the outcome of the trial would have been different. View "Mills v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of operating a vehicle while under the influence of alcohol pursuant to Wyo. Stat. Ann. 31-5-233(b)(i) and (b)(iii), holding that the district court did not abuse its discretion when it admitted evidence of Defendant's blood alcohol concentration (BAC) and that Defendant was not denied due process or an opportunity to conduct an effective cross-examination at trial.On appeal, Defendant argued that the trial court erred by admitting his BAC because the State failed to establish that his blood analysis was performed according to methods approved by the Wyoming Department of Health and that the error was prejudicial. The Supreme Court affirmed, holding (1) the district court should have compelled production of a linearity study related to the calibrator for Defendant's blood samples test, but the error was harmless; and (2) Defendant was not denied his constitutional right to due process or an opportunity to confront the State's witnesses. View "Hardman v. State" on Justia Law