Justia Wyoming Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Court affirmed the judgment of the district court finding Defendant guilty of four counts of sexual abuse of a minor, holding that Defendant knowingly and intelligently waived his Miranda rights and that Defendant did not receive ineffective assistance of counsel.At a hospital, Defendant made incriminating statements to law enforcement officers that he had sexually abused his daughter. Defendant filed a motion to suppress his confessions on the grounds that he was lacking contact with reality when he confessed. The district court denied the motion to suppress, finding that Defendant waived his Miranda rights voluntarily, knowingly, and intelligently. Thereafter, Defendant was convicted. The Supreme Court affirmed, holding (1) Defendant voluntarily waived his Miranda rights; and (2) Defendant's trial counsel provided effective assistance at each phase of Defendant's prosecution. View "Jendresen v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's Wyo. R. App. P. 21 motion asserting that his trial counsel provided ineffective assistance when he failed to raise a challenge under Batson v. Kentucky, 476 U.S. 79 (1986), holding that the district court did not err.Defendant was convicted of conspiracy to commit aggravated robbery. During trial, the State used two peremptory challenge to strike the only minority jurors in the venire. Defendant's counsel failed to raise a Batson challenge to the State's use of peremptory challenges. The Supreme Court affirmed, holding (1) there is no direct appeal of a Batson claim if it was not raised in the trial court; (2) the failure to raise a Batson challenge is not usually structural error when it is brought in the context of an ineffective assistance of counsel claim; (3) the district court correctly ruled that trial counsel was not ineffective for failing to raise a Batson challenge; and (4) the district court had not duty sua sponte to raise Batson on its own under the facts of this case. View "Yazzie v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence obtained at the end of a traffic stop, holding that the traffic stop was unlawfully extended after its initial purpose had been resolved.Defendant entered a conditional plea to methamphetamine possession and child endangerment. Defendant appealed, arguing that the district court erred in denying his motion to suppress evidence obtained at the end of the traffic stop because the stop was unlawfully extended before a drug dog alerted. The Supreme Court agreed, holding (1) Defendant did not waive his argument that the stop was unlawfully extended; and (2) Defendant's Fourth Amendment rights were violated because the law enforcement officer unlawfully extended the duration of the traffic stop after he completed the citation. View "Mahaffy v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of attempted second-degree murder, holding that the overwhelming evidence of guilt precluded a conclusion that any alleged errors were prejudicial.On appeal, Defendant argued that his counsel provided ineffective assistance and that the prosecutor committed prejudicial misconduct. The Supreme Court affirmed, holding that the district court did not err in denying Defendant's motion for a new trial due to ineffective assistance of counsel and that prosecutorial misconduct did not deny Defendant a fair trial. Specifically, the Court held that Defendant failed to demonstrate prejudice, which was dispositive of both of his claims. View "Leners v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court terminating Mother's parental rights to Child, holding that the district court did not err or abuse its discretion.The Wyoming Department of Family Services filed a petition to terminate Mother's parental rights to Child, but Mother failed timely to respond. The clerk of the district court proceeded to enter default against Mother. On appeal, Mother argued that the district court violated her due process rights by holding the evidentiary default hearing by video conference and by not giving her a meaningful chance to be heard regarding Child's best interests. The Supreme Court affirmed, holding that Mother's due process rights were not violated when the district court held the default hearing by video conference or when it limited Mother's participation at the hearing. View "Herden v. State, ex rel. Department of Family Services" on Justia Law

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The Supreme Court affirmed Defendant's conviction of second-degree murder and aggravated assault, holding that the district court did not err in denying Defendant's motion to suppress statements he made at the scene of the crime and during a recorded interview.On appeal, Defendant argued that the admission of the challenged statements violated his rights under the Fifth and Fourteenth Amendment because he was not informed of his Miranda rights before he was questioned and because he was under the influence of methamphetamine at the time of the recorded interview. The Supreme Court affirmed, holding that the district court (1) did not err when it found Defendant's statements at the scene fell under the public safety exception to Miranda; and (2) did not err when it found that Defendant voluntarily waived his Miranda rights at the police station. View "Schwartz v. State" on Justia Law

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The Supreme Court affirmed the orders of the district court denying Appellant's motions to correct an illegal sentence and to withdraw his guilty pleas, holding that the district court did not err.Appellant was serving consecutive life sentences for crimes he committed in Washakie County and Carbon County. In these consolidated appeals, Appellant (1) challenged the Washakie County District Court orders denying his motions to correct an illegal sentence and to withdraw his guilty plea and (2) appealed Carbon County District Court orders imposing sentences consecutive to his Washakie County sentence and denying his Wyo. R. Crim. P. 21 motion. The Supreme Court affirmed the Carbon County sentence and the denial of Appellant's Rule 21 motion, holding (1) the Washakie County District Court lacked jurisdiction to consider Defendant's arguments; (2) the Carbon County sentence did not create an unconstitutional de facto life sentence; and (3) Defendant received effective assistance of counsel at his Carbon County resentencing hearing. View "Sides v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction for possession of a controlled substance, holding that the district court did not err in denying Defendant's motion to suppress under the Fourth Amendment to the United States Constitution and Wyo. Const. art. I, 4.A highway patrol trooper stopped Defendant when he twice observed Defendant's vehicle cross the dotted center white line separating the two lanes of traffic. Marijuana was found in a free-air K-9 sniff during the stop. In his motion to suppress, Defendant argued that his failure to maintain a single lane of travel on the two occasions did not create reasonable suspicion justifying the stop of his vehicle. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the district court did not err in concluding that reasonable suspicion supported the initial stop. View "Elmore v. State" on Justia Law

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The Supreme Court reversed the decision of the district court denying Defendant's motion to suppress evidence discovered after law enforcement entered Defendant's apartment without a warrant to arrest him after he failed to stop for a traffic violation, holding that the district court erred.In denying Defendant's pretrial motion to suppress the district court concluded that the officers' warrantless entry into Defendant's apartment to arrest him was constitutional under the hot pursuit exception to the Fourth Amendment's warrant requirement. The Supreme Court reversed, holding that, under the circumstances, there was no compelling need requiring immediate police action. View "Fuller v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of two controlled substance charges, holding that the district court did not err in denying Defendant's motion to suppress evidence found during a search of the rental van he was driving.Defendant was charged with four drug-related felonies. Defendant moved to suppress evidence found in the rental van that he was driving, arguing that law enforcement violated his Fourth Amendment rights against unreasonable search and seizure when they detained him for the purpose of having a dog unit arrive of scene. The trial court denied the motion. The Supreme Court affirmed, holding that the district court did not err when it denied Defendant's motion to suppress because law enforcement did not violate Defendant's constitutional rights under the Fourth Amendment. View "Pryce v. State" on Justia Law