Justia Wyoming Supreme Court Opinion Summaries

Appellant Justin Sadler was convicted by jury of aggravated assault. Prior to his state trial, Sadler was convicted in federal court of being a felon in possession of a firearm, based on the same circumstances that gave rise to his state charges. The State indicated that it would seek to admit this prior conviction under W.R.E. 609(b) if Sadler testified. The district court reserved ruling on whether Sadler’s federal conviction would be admissible, however, it observed that if Sadler denied possessing the firearm, the probative value of the prior conviction “escalates off the charts.” Sadler elected not to testify at trial. On appeal of his state charges, Sadler challenged the propriety of the district court’s comments, claiming that the court improperly chilled the exercise of his constitutional right to defend himself by testifying on his own behalf. Because he did not preserve the issue he raised on appeal, the Wyoming Supreme Court affirmed. View "Sadler v. Wyoming" on Justia Law

Appellant Marvin Clay challenged the denial of his motion to suppress evidence supporting a conviction for driving under the influence of alcohol. The officer testified that he made the stop because the car did not have any license plates displayed. All he could see at that point was a white piece of paper in the upper left corner of the rear window, which was heavily tinted. Because he was unable to verify that the white piece of paper was a document which would allow Appellant to operate the vehicle temporarily, the officer approached the car and talked to him. He asked about the paper and if there was a bill of sale. The document in the window turned out to be a title, but more than forty-five days had elapsed since the transfer, and the officer could not tell if it was notarized, both of which were required for operation of the vehicle to be legal. Appellant said there was a bill of sale, and opened his wallet and started thumbing through it for that document, but he never pulled anything out. Appellant could not provide a driver’s license or proof of insurance either. Within the first minute of Appellant slowly flipping through his wallet, the officer observed signs of possible intoxication. A DUI Task Force officer was called, and three field sobriety tests were performed. Appellant "performed poorly" on all three. Appellant was ultimately charged, inter alia, with Driving Under the Influence, Fourth Offense. On appeal, Appellant argued that his detention was improperly expanded beyond the scope of the initial traffic stop, and that the evidence used to support the DUI arrest was discovered only after the unnecessary contact and therefore ought to have been suppressed. Finding no error in the trial court's decision, the Supreme Court affirmed. View "Clay v. Wyoming" on Justia Law

Appellant Jeffery Lafferty was incarcerated awaiting trial for 811 days before pleading guilty to two counts of taking indecent liberties with his minor stepdaughter. After balancing the required factors, the district court concluded that the delay in bringing Lafferty to trial was reasonable and did not impair his right to a fair trial. On appeal, he argued his constitutional right to a speedy trial was violated. A review of the record revealed to the Wyoming Supreme Court that much of the delay was the result of appellant's own actions, "which in the aggregate caused his case to go on the circuitous journey it did." As such, the Court found no violation of appellant's constitutional right to a speedy trial and affirmed his convictions. View "Lafferty v. Wyoming" on Justia Law

Defendant pleaded guilty to misdemeanor breach of peace and misdemeanor interference with a peace officer. Two days later, the State filed an information charging Defendant with felony interference with a peace officer arising out of the same events as those underlying his misdemeanors convictions. Defendant entered an unconditional plea of no contest to a reduced charge of misdemeanor interference. Defendant appealed, arguing that his second misdemeanor conviction violated his double jeopardy protections. The Supreme Court affirmed, holding (1) Defendant did not waive his double jeopardy claim; and (2) because Defendant committed two separate acts of interference, one inside his home and one outside his home, Defendant could lawfully be prosecuted for each separate offense. View "Redding v. State" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault and battery. Defendant appealed, arguing that the prosecutor committed prosecutorial misconduct by incorrectly instructing the jury regarding the presumption of innocence and by attempting to define “reasonable doubt” to the jury in his closing argument. The Supreme Court affirmed, holding (1) the prosecutor violated a clear and unequivocal rule of law when he made an incorrect statement regarding the presumption of innocence; (2) the prosecutor transgressed a clear and unequivocal rule of law when he defined reasonable doubt for the jury in his closing argument; but (3) while Defendant established that the prosecutor committed two errors that transgressed clear and unequivocal rules of law, the cumulative effect of these errors was not prejudicial. View "Watts v. State" on Justia Law

After a jury trial, Defendant was found guilty of five counts of reckless endangering, three counts of aggravated assault, and one count of eluding police. The Supreme Court affirmed, holding (1) there was sufficient evidence presented at trial to convict Defendant of aggravated assault; (2) the district court erred in admitting evidence of law enforcement officers’ subjective reactions to a fired shot, but the error was not prejudicial; (3) the district court did not abuse its discretion when it denied Defendant’s motion for mistrial based upon prosecutorial misconduct; and (4) the prosecutor’s comments during closing argument did not constitute plain error. View "Hill v. State" on Justia Law

After a jury trial, Defendant was found guilty of four counts of first degree sexual abuse involving two minors. Defendant was sentenced to life in prison without the possibility of parole. The Supreme Court affirmed, holding (1) the district court did not err by (i) rejecting Defendant’s ineffective assistance of counsel claim, (ii) determining that the child witnesses were competent to testify, (iii) denying Defendant’s requests for continuances, and (iv) admitting other bad acts evidence under Wyo. R. Evid. 404(b); (2) the district court erred in allowing the admission of some hearsay testimony at trial, but the errors were harmless; and (3) Defendant’s constitutional right to a speedy trial was not violated. View "Griggs v. State" on Justia Law

Pursuant to a plea agreement, Defendant pled guilty to one count of first-degree sexual abuse of a minor. Defendant later filed a motion for sentence modification or reduction under newly discovered evidence arguing that his guilty plea was involuntary and that his trial counsel provided ineffective assistance. The district court construed the motion as both a motion to withdraw Defendant’s guilty plea and to reduce Defendant’s sentence. The district court denied the request to withdraw Defendant’s guilty plea, concluding that Defendant failed to establish newly discovered evidence resulting in manifest injustice, and concluded that it did not have jurisdiction to consider a sentence reduction because Defendant’s motion was untimely. Defendant appealed. The Supreme Court dismissed the appeal, holding that the district court did not have jurisdiction to rule on Defendant’s motion, and therefore, this Court did not have jurisdiction to consider Defendant’s appeal. View "Shue v. State" on Justia Law

Appellant filed a 42 U.S.C. 1983 civil rights action in the district court asserting four federal constitutional claims and one state law claim, alleging that, while he was an inmate in the state of Wyoming under the supervision and control of the Wyoming Department of Corrections (DOC), he was deprived of his personal property, which violated his right to due process and caused him injury. The district court granted summary judgment on all claims for the DOC. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of the DOC. View "Chapman v. Wyo. Dep’t of Corr." on Justia Law

After a jury trial, Defendant was found guilty of domestic battery and possession of a weapon with intent to threaten. Defendant appealed, arguing (1) the prosecutor improperly asked him a series of questions during his testimony at trial in which the prosecutor repeated statements made by Defendant’s daughter and asked, “was she lying?”; and (2) the district court abused its discretion when it allowed evidence of prior discharge of a gun. The Supreme Court reversed, holding (1) the prosecutor’s questioning was improper, and the error was prejudicial; and (2) the absence of appropriate findings and discussion regarding the admission of the discharge evidence hinders review of the district court’s decision to admit the evidence. Remanded. View "McGinn v. State" on Justia Law