Justia Wyoming Supreme Court Opinion Summaries

A police officer in Casper, Wyoming, observed a pickup truck driven by Mark Davis traveling slowly and approaching a stop sign. The officer noticed Davis activated his right turn signal only shortly before stopping at the intersection, estimating the signal was turned on no more than twenty feet before the turn, rather than the statutorily required 100 feet. After stopping Davis, the officer discovered an open beer can and learned Davis’s license was suspended. A subsequent search of the vehicle revealed methamphetamine, marijuana, and drug paraphernalia. Davis was charged with felony possession of methamphetamine and felony possession with intent to deliver.Davis filed a motion to suppress the evidence, arguing the officer lacked reasonable suspicion for the traffic stop because he had activated his turn signal more than 100 feet before the turn. At the suppression hearing in the District Court of Natrona County, the officer testified about his training in estimating distances, and Davis’s expert witness presented calculations based on the dash cam video, but conceded uncertainty about Davis’s speed. The district court reviewed the video and testimony, ultimately finding the officer’s estimate credible and concluding the State met its burden to show reasonable suspicion for the stop. The court denied the motion to suppress, and Davis entered a conditional guilty plea, reserving his right to appeal.On appeal, the Supreme Court of Wyoming reviewed the district court’s denial of the suppression motion, deferring to its factual findings unless clearly erroneous and reviewing constitutional questions de novo. The Supreme Court held that, under the totality of the circumstances, the officer had reasonable suspicion to believe Davis violated the turn signal statute, justifying the stop. The district court’s findings were supported by the record, and the evidence obtained was admissible. The judgment was affirmed. View "Davis v. The State of Wyoming" on Justia Law

A nineteen-year-old man was convicted for his involvement in two murders in Wyoming. He was sentenced in 2006 to three consecutive terms of life imprisonment without the possibility of parole, following a jury trial in which he was acquitted of one count of first-degree murder but convicted of conspiracy to commit murder and first-degree murder for the other offenses. The crimes involved the killing of a roommate and a sixteen-year-old, with the defendant playing a significant role in both. At sentencing, the jury declined to impose the death penalty and instead issued mandatory life without parole sentences, as required by Wyoming law at the time.After his direct appeal was denied by the Wyoming Supreme Court, the defendant filed a motion in 2024 to correct his sentences, arguing that mandatory life without parole for “emerging adults” (those aged eighteen to twenty-one) is unconstitutional under both the Wyoming and United States Constitutions. He claimed that new scientific evidence and evolving legal standards, particularly those established in Miller v. Alabama and related U.S. Supreme Court cases, should extend protections against mandatory life without parole to offenders in his age group. The District Court of Campbell County denied his motion, finding that the relevant constitutional protections and precedents did not apply to adults over eighteen.The Supreme Court of Wyoming reviewed the case and affirmed the district court’s decision. The court held that the Wyoming Constitution does not provide broader categorical protections for “emerging adults” than the Eighth Amendment. It concluded that the state’s constitutional provisions on cruel or unusual punishment and on the penal code’s humane principles do not prohibit mandatory life without parole sentences for offenders over eighteen. The court also found no violation of equal protection or entitlement to a new sentencing hearing. The holding clarified that, while Wyoming’s constitution is distinct from the federal constitution, it does not require categorical relief for emerging adults sentenced to life without parole. View "Hicks v. The State of Wyoming" on Justia Law

A law enforcement officer observed a black sedan at a busy intersection in Campbell County, Wyoming. The sedan, driven by Andrew Boyer, was in the right lane behind an SUV. When the light turned green, the SUV did not move, and Boyer overtook it on the right to turn east, remaining on the paved surface. The officer, concerned about the safety of this maneuver and suspecting a traffic violation, followed Boyer. While following, dispatch informed the officer that the vehicle’s registered owner, Boyer, did not have a valid driver’s license. After stopping Boyer, the officer confirmed his identity and learned he possessed a physical license, though the officer knew this did not guarantee valid driving privileges. During the stop, a K-9 unit alerted to drugs in the vehicle, leading to a search that uncovered methamphetamine, marijuana, and drug paraphernalia.Boyer was charged with several drug-related offenses and moved to suppress the evidence, arguing the stop was not supported by reasonable suspicion and that the scope of the stop was improperly expanded. The District Court of Campbell County denied the motion, finding the officer had reasonable suspicion both from observing the overtaking maneuver and from dispatch’s information about Boyer’s license status. The court also found the stop was not unnecessarily prolonged.On appeal, the Supreme Court of Wyoming reviewed whether the district court erred in denying the motion to suppress. The court held that the officer had reasonable suspicion to justify the initial stop based on both the observed traffic violation and the information from dispatch regarding Boyer’s license. The court concluded that the stop did not violate the Fourth Amendment, as the officer’s actions were reasonable under the totality of the circumstances. The Supreme Court of Wyoming affirmed the district court’s denial of the motion to suppress. View "Boyer v. The State of Wyoming" on Justia Law

Logan Gregory Gosselin pled guilty to one count of sexual exploitation of a child and was sentenced to three to eight years in prison, with a recommendation for the Youthful Offender Transition Program (YOTP). Nearing completion of the YOTP, Gosselin filed a motion for sentence reduction, which the district court denied. Gosselin appealed, arguing that the district court abused its discretion and violated his constitutional rights by not honoring an earlier promise to reduce his sentence upon successful completion of the YOTP.The district court of Laramie County initially sentenced Gosselin and included a written judgment suggesting an expectation of sentence reduction if he completed the YOTP. However, the judge who issued the original sentence retired, and a new judge denied Gosselin's motion for sentence reduction without a hearing. Gosselin's appeal contended that the denial was an abuse of discretion and violated his due process and double jeopardy rights.The Wyoming Supreme Court reviewed the case and found that the district court did not abuse its discretion. The court clarified that the written judgment's language about an "expectation" of sentence reduction did not constitute a binding promise. The court also determined that the district court's oral pronouncement did not guarantee a sentence reduction but merely indicated that Gosselin would likely return to court to request it. The Supreme Court held that the district court's denial of the motion did not violate Gosselin's due process rights, as there was no protected interest in a guaranteed sentence reduction. Additionally, the court found no double jeopardy violation, as the denial of the motion did not increase Gosselin's original sentence. The Wyoming Supreme Court affirmed the district court's decision. View "Gosselin v. State" on Justia Law

Clifford Bain was seriously injured when a bus owned and operated by the City of Cheyenne collided with him while he was riding his motorcycle. Bain filed a complaint against the bus driver and the City under the Wyoming Governmental Claims Act (WGCA). The bus driver and the City admitted liability but claimed immunity from any liability exceeding $250,000 under the WGCA. Bain then filed a motion for partial summary judgment, arguing that the limitation in § 1-39-118(a)(i) of the WGCA was unconstitutional under Article 10, § 4(a) of the Wyoming Constitution. The district court denied Bain’s motion, declaring the statute constitutional. Bain subsequently filed a petition for writ of review with the Wyoming Supreme Court.The district court denied Bain’s motion for partial summary judgment, holding that § 1-39-118(a)(i) of the WGCA is not a limitation on damages but rather a limitation on the waiver of immunity. Bain then filed a petition for writ of review, which the Wyoming Supreme Court granted.The Wyoming Supreme Court reviewed the case de novo and affirmed the district court’s decision. The Court held that § 1-39-118(a)(i) is a limitation on the waiver of immunity under the WGCA and not a limitation on damages, thus it does not violate Article 10, § 4(a) of the Wyoming Constitution. The Court emphasized that the statute limits the legal responsibility or obligation of governmental entities and is consistent with the legislative intent to balance the equities between injured persons and taxpayers. The Court concluded that Bain did not meet his burden of proving the statute unconstitutional. View "Bain v. City of Cheyenne" on Justia Law

Sandra Malone (Grandmother) filed a lawsuit against Salvador Galvan (Father) seeking visitation rights with ALG, the child of her deceased daughter. Father and Mother had a child, ALG, in July 2022. They regularly attended family dinners with Mother’s family, including Grandmother. After Mother’s death in an ATV accident caused by Father, Grandmother accused Father of killing Mother and supported his criminal prosecution. Father, concerned about Grandmother’s negative impact on ALG, stopped attending family dinners and discontinued visits between ALG and Grandmother, although he maintained relationships with other family members.The District Court of Albany County held a trial and granted Grandmother visitation rights. The court found that Grandmother had a significant preexisting relationship with ALG and concluded that Father’s decision to discontinue visits with Grandmother was harmful to ALG. The court awarded Grandmother visitation despite acknowledging concerns about her animosity towards Father and the potential negative impact on ALG.The Supreme Court of Wyoming reviewed the case. The court held that the district court erred in its findings. It emphasized that Grandmother needed to prove by clear and convincing evidence that Father’s decision to restrict visitation was harmful to ALG. The court found that Grandmother did not present any evidence of harm, while Father’s expert testified that visitation with Grandmother could harm ALG due to the hostile relationship between Father and Grandmother. The Supreme Court concluded that the district court violated Father’s constitutional rights as a parent by granting Grandmother visitation without sufficient evidence of harm to ALG.The Supreme Court of Wyoming reversed the district court’s decision, holding that the lower court clearly erred in finding that Grandmother established harm by clear and convincing evidence. View "Galvan v. Malone" on Justia Law

David Herrera, Jr. pled guilty to aggravated robbery with a deadly weapon and was sentenced to five to eight years in prison by the district court, which recommended his placement in the Youthful Offender Transition Program (YOTP). Herrera filed a motion for sentence reduction upon nearing completion of the YOTP, asserting that the district court had promised to reduce his sentence if he successfully completed the program.The district court denied Herrera’s motion for sentence reduction without holding a hearing or providing an explanation. Herrera appealed, arguing that the district court abused its discretion and violated his constitutional rights by not honoring the promise made during sentencing.The Wyoming Supreme Court reviewed the case and found that the district court’s oral pronouncement at sentencing, which stated Herrera “will get a sentence reduction” if he completed the YOTP, constituted an express commitment. The court held that the district court abused its discretion by denying the motion for sentence reduction without justification, given the prior commitment. The Supreme Court reversed the district court’s decision and remanded the case for further sentencing proceedings consistent with its opinion. View "Herrera v. The State of Wyoming" on Justia Law

William Patterson was convicted of sexually abusing his girlfriend’s four-year-old niece. The incident occurred on September 15, 2019, when Patterson was watching the child and her twin sister. The children later reported the abuse to their mother, who contacted the police. The children were interviewed, and one disclosed the abuse. However, the district attorney initially decided not to charge Patterson. Three years later, the children provided more details, leading to charges against Patterson. He was convicted by a jury of second and third-degree sexual abuse of a minor.The District Court of Natrona County sentenced Patterson to 14-20 years in prison for second-degree sexual abuse of a minor, noting that the same act formed the basis for both convictions. Patterson appealed, arguing that the prosecutor improperly commented on his right to remain silent during the trial. The district court had denied Patterson’s motion for a mistrial, concluding that the prosecutor’s statement was not an improper comment on his right to remain silent and that any potential prejudice was mitigated by the court’s curative actions.The Supreme Court of Wyoming reviewed the case and determined that the prosecutor’s statement during opening arguments, which mentioned Patterson’s refusal to speak with law enforcement, was an impermissible comment on his constitutional right to remain silent. The court reaffirmed that such comments are prejudicial per se under the Wyoming Constitution and require reversal of the conviction. The court overruled previous case law that allowed for a distinction between a “comment” and a “reference” to silence, clarifying that any improper comment on the right to silence is prejudicial per se. Consequently, the Supreme Court of Wyoming reversed Patterson’s conviction and remanded the case for a new trial. View "Patterson v. State" on Justia Law

Joseph W. Russell entered a conditional guilty plea to possession of methamphetamine, reserving his right to appeal the constitutionality of a warrantless search conducted as he entered the Uinta County Courthouse. The search, performed by Deputy Dan Jensen, involved a magnetometer alerting to metal in Russell's waist area, leading to a pat-down and the discovery of a snus can containing methamphetamine. Russell was charged with felony possession of a controlled substance.The district court denied Russell's motion to suppress the evidence, finding the search reasonable under the Fourth Amendment. Russell entered a conditional guilty plea, allowing him to appeal the suppression order. He was sentenced to one to three years of imprisonment, suspended in favor of two years of supervised probation. Russell timely appealed the denial of his motion to suppress.The Wyoming Supreme Court reviewed the case, focusing on whether the search violated the Fourth Amendment. The court applied a three-part test to determine the reasonableness of the search: the nature and immediacy of the governmental concern, the efficacy of the search in addressing that concern, and the nature of the privacy interest upon which the search intrudes. The court found that courthouse security is a compelling governmental interest, the use of a magnetometer and follow-up searches are effective in addressing this concern, and the privacy interest in the snus can was minimal given the context of courthouse security.The court concluded that the search was reasonable and affirmed the district court's denial of Russell's motion to suppress. The holding emphasized that the search was justified under the special needs exception to the Fourth Amendment, balancing the government's interest in courthouse security against the minimal intrusion on Russell's privacy. View "Russell v. State" on Justia Law

Amy Romero was arrested for driving while under the influence of alcohol (DWUI) after being found stuck in a snowbank. Officer George Phillips of the Rawlins Police Department noticed the vehicle and, upon investigation, detected a strong odor of alcohol from Ms. Romero. During the interaction, Ms. Romero admitted to driving the vehicle and exhibited signs of intoxication. Officer Phillips placed her in the back of his patrol car to deescalate a potentially violent situation with her husband, Joseph Romero, who was also present and behaving aggressively.The Office of Administrative Hearings (OAH) upheld the suspension of Ms. Romero’s driver’s license, concluding that Officer Phillips had reasonable suspicion to detain her for a DWUI investigation. The OAH found that the officer’s actions, including placing Ms. Romero in the patrol car and transporting her to a dry environment for field sobriety tests, were justified based on the totality of the circumstances, including the strong odor of alcohol, her admission of driving, and the need to manage her husband’s aggressive behavior.The Wyoming Supreme Court reviewed the case and affirmed the OAH’s decision. The Court held that Officer Phillips’ detention of Ms. Romero in the back of the patrol car did not constitute an unlawful arrest but was a reasonable investigative detention supported by substantial evidence. The Court found that the officer’s actions were necessary to ensure safety and were within the scope of a lawful investigative detention. The Court concluded that the OAH’s findings were supported by substantial evidence and that the detention was in accordance with constitutional protections. The decision to uphold the suspension of Ms. Romero’s driver’s license was affirmed. View "Romero v. State of Wyoming Ex Rel., Wyoming Department of Transportation" on Justia Law