Justia Wyoming Supreme Court Opinion Summaries

Steven McLaren challenged his convictions for five felonies stemming from a bizarre and violent encounter with his girlfriend in 2014. McLaren owned 57 cats. He and his girlfriend, Jennifer Evans, referred to the cats as their “kids” or “the kid.” In March 2014, one of Mr. McLaren’s exotic Savannah kittens, Cameo, was sick, so he and Evans took it to a veterinary clinic for treatment. McLaren testified that he had injected “somewhere between a quarter and a third of a gram” of methamphetamine right before he noticed Cameo was ill, had not slept for days, and had been experiencing hallucinations since the night before. He was under the impression that Evans was attempting to harm or kill the kitten. After taking the kitten to the vet, McLaren and Evans drove around for a time. Though nothing seemed out of the ordinary at that time, McLaren came to a complete stop in the southbound lane in front of an oncoming Pepsi truck. Evans attempted to get out of the truck, but he pulled her by her hair back into the truck and locked the doors, telling her that her “kids deserved a better mother” and that she “was going to die today.” The Pepsi truck swerved around them, and McLaren turned off Highway 191, onto Wild Horse Loop. As he drove down Wild Horse Loop, Evans fought with McLaren and continued to attempt to get out, kicking the truck into park several times. McLaren also continued to hit and punch Evans; he grabbed her throat and forced her to the floorboard of the truck. At some point, McLaren opened the passenger door and Evans fell. She testified that McLaren stood over her, pulled her head to the left and the right, “trying to rip my head off,” and then let go. As soon as McLaren released her, Evans got up and ran toward Highway 191, where a truck stopped to assist her. When Evans arrived at the emergency room, she had two lacerations on her head and numerous bruises. Appealing his felonies, McLaren argued the trial court violated his due process rights when it failed to order a third competency evaluation and when it allowed defense counsel to assert a plea of not guilty by reason of mental illness (NGMI) against his will. He also argued the jury instructions contained structural error because they did not require the State to prove he did not act in a sudden heat of passion to establish attempted second-degree murder and that the trial court abused its discretion when it denied defense counsel’s motion for mistrial after McLaren’s outburst during trial. The Wyoming Supreme Court concluded that, while the trial court did not improperly fail to order a competency hearing, it violated McLaren’s due process rights when, in spite of McLaren’s numerous declarations that he did not wish to proceed with the NGMI plea, it allowed defense counsel to assert the plea at trial. View "McLaren v. Wyoming" on Justia Law

A jury convicted appellant Donald Dean Foltz, Jr. of first-degree murder and the district court sentenced him to life without the possibility of parole. Foltz was accused of child abuse towards his girlfriend’s two-year-old son. Foltz appealed his conviction, arguing the district court erred when it denied his motion for judgment of acquittal because he contended the evidence was insufficient to support the charged against him. After review of the trial court record, the Wyoming Supreme Court found no reversible error and affirmed Foltz’s conviction. View "Foltz, Jr. v. Wyoming" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Appellant’s declaratory judgment action for lack of a justiciable controversy.Appellant’s driver’s license was suspended after her agreed to take a breath test and provided a breath sample indicating his blood alcohol concentration to be over the legal limit. Appellant initiated a civil action seeking a declaratory judgment that the Wyoming Constitution prohibits a law enforcement officer from using the “deemed consent” provision of Wyo. Stat. Ann. 31-6-102(a)(i) to perform a warrantless chemical test incident to the lawful arrest of a motorist. The district court concluded that the request did not present a justiciable controversy and granted the Wyoming Department of Transportation’s motion to dismiss the action. The Supreme Court affirmed, holding that the district court properly dismissed the claim because Appellant failed to present a justiciable controversy. View "Leavitt v. State, ex rel. Wyoming Department of Transportation" on Justia Law

The Supreme Court reversed Appellant’s conviction for aggravated assault entered after a jury trial. The district court sentence Appellant to life in prison. The Supreme Court held (1) the prosecutor’s failure to comply with the court’s discovery order constituted misconduct; (2) the district court abused its discretion in denying Appellant’s motion to restrict witness testimony; (3) the prosecutor committed misconduct during closing argument; (4) Appellant was denied due process of law because he was required to wear a leg brace in the presence of the jury; and (5) because of the cumulative effect of these errors, Appellant was denied a fair trial. View "Black v. State" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion requesting that the criminal case against him be dismissed based upon the Fifth Amendment’s prohibition against double jeopardy.A jury convicted Defendant of felonious restraint, strangulation of a household member, and domestic battery. Defendant’s first trial resulted in a mistrial at Defendant’s request after the district court concluded that the prosecutor asked Defendant improper questions during cross-examination. Before the second trial commenced, Defendant filed a motion to dismiss the charges against him based on the Fifth Amendment’s prohibition against double jeopardy. The district court denied the motion, explaining that there was no evidence that suggested the State had intentionally goaded Defendant into requesting a mistrial. Defendant was subsequently found guilty of felonious restraint, strangulation of a household member, and domestic battery. The Supreme Court affirmed, holding that the district court’s finding that the prosecutor did not goad Defendant into requesting a mistrial was not clearly erroneous. View "King v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions on one charge of domestic battery and one charge of strangulation of a household member. On appeal, Defendant argued that his convictions and sentences for both crimes violated his constitutional protections against double jeopardy because domestic battery is a lesser included offense of strangulation of a household member. The Supreme Court held that the district court did not commit plain error when it convicted and sentenced Defendant for the crimes of domestic battery and strangulation of a household member because Defendant’s two convictions arose from separate and distinct conduct, and therefore, Defendant failed to establish a double jeopardy violation. View "Drakeford v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions of three counts of sexual abuse of a minor in the second degree and one count of sexual abuse of a minor in the third degree for Defendant’s sexual abuse of the daughter of his girlfriend. Defendant appealed, arguing that his trial counsel provided ineffective assistance in multiple ways and that the district court committed reversible error. In affirming, the Supreme Court held (1) Defendant’s trial counsel was not ineffective in her representation of Defendant; and (2) there was no reversible error on the part of the district court. View "Woods v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions of two counts of aggravated assault and battery with a deadly weapon, one count of felony property destruction, and one count of attempted second degree murder. The court held (1) Defendant received a speedy trial as required by Wyo. R. Crim. P. 43 and the federal and state Constitutions; (2) the prosecutor did not commit misconduct during closing arguments; (3) Defendant received effective assistance of trial counsel; (4) the district court properly instructed the jury that it may infer malice from Defendant’s use of a deadly weapon; and (5) the district court did not violate Defendant’s constitutional protection against double jeopardy when it imposed separate sentences for aggravated assault and battery with a deadly weapon and attempted second degree murder. View "Webb v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction, rendered after a jury trial, of one count of domestic battery and one count of strangulation of a household member for attacking his girlfriend. On appeal, Defendant argued that the district court violated his constitutional right of confrontation when it refused testimony about the victim’s prior relationship from the sister of the victim’s former boyfriend. The Supreme Court disagreed, holding that the district court did not err by excluding the testimony under the rules of evidence and the court’s case law interpreting them. View "Garland v. State" on Justia Law

Defendant was sixteen years old when he committed the crimes at issue in this case. The Supreme Court affirmed Defendant’s convictions of one count of first-degree murder, one count of aggravated assault and battery, and ten counts of attempted aggravated assault and battery but reversed Defendant’s sentence and remanded for resentencing. The court held (1) the district court did not abuse its discretion when it denied Defendant’s motion to transfer the proceedings to juvenile court; (2) there were some errors in the jury instructions, but the errors were not prejudicial either individually or cumulatively; (3) the prosecutor’s victim impact statements during closing arguments were improper but not prejudicial; (4) there was sufficient evidence to support the attempted assault and battery charges; (5) Defendant’s aggregate sentence did not deprive the parole board of its statutory authority to consider parole of juveniles after twenty-five years; (6) Defendant’s sentence for murder and aggravated assault of the same victim did not violate double jeopardy; but (7) Defendant’s aggregate sentence violated the Eighth Amendment because it was a de facto life without parole sentence. View "Sam v. State" on Justia Law