Justia Wyoming Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Court affirmed Defendant's convictions of aggravated assault and battery, domestic battery, strangulation of a household member, violating a protective order, and witness intimidation, holding that there was one trial error in a single incident of prosecutorial misconduct, but Defendant suffered no prejudice from the comment. Specifically, the Court held (1) the district court did not err in denying Defendant's motion for a new trial based on the State's alleged failure to disclose exculpatory evidence; (2) the district court did not err in denying Defendant's motion for a new trial based on claims of ineffective assistance of counsel; (3) the State committed prosecutorial misconduct by vouching for the credibility of the victim, but the comment was not prejudicial; (4) the district court did not err in joining charges against Defendant for trial; (5) the district court did not err in denying Defendant's motion for a Daubert hearing on the testimony of the State's domestic violence expert; and (6) cumulative error did not warrant reversal of Defendant's conviction. View "Byerly v. State" on Justia Law

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The Supreme Court affirmed the district court's denial of Defendant's motion to suppress evidence obtained after a search of his camper, holding that the search warrant contained sufficient untainted evidence to establish probable cause to search the camper. Defendant was charged with possession with intent to deliver a controlled substance and possession of a controlled substance. Defendant filed a motion to suppress, challenging the reasonableness of a search on September 8, 2017 and the probable cause for search warrants issued on September 9, 2017 and September 12, 2017. The district court denied the motion to suppress, and Defendant entered a conditional guilty plea to possession of a controlled substance. The Supreme Court affirmed, holding (1) Defendant's guilty plea did not preserve a Franks argument; and (2) even assuming the law enforcement officer unconstitutionally searched the camper when he opened plastic covering to look through a window on September 8, the warrant affidavit established probable cause through evidence attributable to the officer's unchallenged look through another window. View "Workman v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained from the search of Defendant's vehicle, holding that the law enforcement officer did not violate Defendant's Fourth Amendment rights by detaining him for a drug-dog sniff of his vehicle. Defendant pleaded guilty to possession of more than three ounces of marijuana. Defendant verbally reserved the right to appeal the district court's denial of his motion to suppress. The Supreme Court affirmed the denial of Defendant's motion to suppress, holding (1) while conditional plea agreements are typically required, under the unique circumstances of this case this Court exercises its discretion to review the verbally-reserved issue; and (2) Defendant was not seized in violation of the Fourth Amendment when the officer stopped him for following another vehicle too closely, and Defendant had reasonable suspicion justifying detaining Defendant for a drug-dog sniff of the vehicle. View "Robinson v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of attempted sexual abuse of a minor in the second degree, holding that errors in the jury instructions and any deficiencies in defense counsel's performance associated with the instructions were not prejudicial. Specifically, the Court held (1) the evidence presented at trial was sufficient to convict Defendant of attempted sexual abuse of a minor in the second degree; (2) the jury instructions on the elements of attempted sexual abuse of a minor in the second degree were incorrect; (3) it was unnecessary to discuss in detail whether defense counsel's performance in addressing the jury instructions was deficient; and (4) Defendant was not prejudiced by incorrect jury instructions and/or his counsel's deficient performance because the State presented overwhelming showing Defendant was guilty of the crime. View "Weston v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of stalking, in violation of Wyo. Stat. Ann. 62-506(b) and (e)(I), holding that Defendant's First Amendment right to free speech was not violated when he was prosecuted for writing absence letters to the victim. Specifically, the Supreme Court held (1) Defendant's right to free speech under the First Amendment was not violated when the State prosecuted him under section 6-2-506 for sending obscene letters to the victim, and the evidence was sufficient to support the jury's conclusion that the letters were obscene under the ordinary meaning of that term; (2) the district court did not err in instructing the jury or by refusing Defendant's request for a special verdict form; (3) the State presented sufficient evidence to establish that Defendant harassed the victim; and (4) the district court did not abuse its discretion by admitting evidence that Defendant had been warned not to send unsolicited letters. View "Dugan v. State" on Justia Law

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The Supreme Court affirmed Defendant's aggregate sentence that left him eligible for parole after serving thirty-five years, holding that Defendant failed to show a constitutional violation or an abuse of discretion in the district court's sentencing decision. Defendant was convicted of one count of first-degree murder and twelve counts of aggravated assault and battery for crimes he committed at age sixteen. The district court sentenced Defendant to an aggregate prison term that left him eligible for parole after fifty-two years. The Supreme Court reversed the sentence and remanded for resentencing, holding that the sentence violated the Eighth Amendment because it was a de facto life without parole sentence. On remand, the district court imposed an aggregate sentence that left Defendant eligible for parole after serving thirty-five years. The Supreme Court affirmed, holding that Defendant's sentence did not violate the Eighth Amendment and that the district court did not abuse its discretion in sentencing Defendant. View "Sam v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Defendant's motions to withdraw his no contest plea to driving under the influence of alcohol, holding that Defendant's no contest plea was not knowing or voluntary, and therefore, the district court abused its discretion in denying Defendant's motions to withdraw his plea. On appeal, Defendant argued that his plea was not knowing or voluntary because the totality of the circumstances showed he did not fully understand the amended charge, the plea agreement, or the consequences of his plea. Further, Defendant claimed that he had insufficient time to speak with his attorney to discuss these matters prior to pleading guilty. The Supreme Court agreed, holding (1) under the specific circumstances of this case, Defendant's plea was not knowing or voluntary; and (2) the district court abused its discretion in not allowing Defendant to withdraw his no contest plea. View "Steffey v. State" on Justia Law

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The Supreme Court reversed Defendant's conviction of sexual assault in the first degree, holding that cumulative error resulting from prosecutorial misconduct deprived Defendant of a fair trial. On appeal, Defendant argued that the prosecutors committed numerous instances of misconduct during the state's case-in-chief and during the State's closing and rebuttal arguments. The Supreme Court remanded the case for a new trial, holding (1) the prosecutor violated the district court's Wyo. R. Evid. 404(b) order; (2) both prosecutors engaged in improper victim impact argument unrelated to credibility; (3) the prosecutor repeatedly argued facts that were not in evidence; (4) the prosecutor intentionally used inflammatory language in closing argument; and (5) cumulative error deprived Defendant of a fair trial. View "Bogard v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of three counts of child endangerment and one count of possession of a controlled substance, holding that the district court did not violate Defendant's Fifth Amendment right to remain silent by admitting testimony regarding Defendant's contamination of a compelled urine sample. On appeal, Defendant argued that evidence of her contamination of the urine sample was admitted in violation of her right to remain silence because the contamination communicated her guilty knowledge or consciousness of guilt. The State raised the additional question of whether Defendant waived her Fifth Amendment claim when she failed to raise it in the district court. The Supreme Court affirmed, holding (1) Defendant had good cause for failing to raise her Fifth Amendment claim before trial so the claim was not waived; and (2) Defendant's decision to contaminate her sample was neither a communicative act nor an act compelled by the State, and therefore, evidence of Defendant's actions was not protected by the Fifth Amendment, and there was no plain error in the admission of the evidence. View "Herrera v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court granting summary judgment in favor of the University of Wyoming (UW) and dismissing Plaintiff's declaratory judgment action, arguing that the district court abused its discretion in concluding that this declaratory judgment action challenging the legality of a UW regulation barring firearms on the UW campus served a useful purpose. Plaintiff was cited for misdemeanor criminal trespass after he refused to either relinquish his handgun, which he brought to a UW facility. Plaintiff pleaded not guilty in circuit court, obtained a stay of the criminal proceedings, and filed an action for declaratory judgment in district court, arguing that the regulation violated his constitutional right to bear arms. The district court granted summary judgment for UW. The Supreme Court reversed with instructions so that the matter may proceed in the circuit court, holding (1) Defendant had standing the challenge the legality of the regulation because of the pending criminal charge against him; and (2) the district court abused its discretion in concluding that this declaratory judgment action served a useful purpose. View "Williams v. State ex rel., University of Wyoming Board of Trustees" on Justia Law