Justia Wyoming Supreme Court Opinion Summaries

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

A highway patrol trooper pulled over the driver of a vehicle for following too closely and for having a cracked windshield. Appellant was seated in the front passenger seat. After Appellant appeared to have suffered a seizure, the trooper searched the pocket of Appellant’s jacket, which Appellant had left in the car, and discovered marijuana. Appellant moved to suppress the evidence found by the trooper during his search of the jacket and the vehicle. The district court denied the motion. Thereafter, Appellant entered a conditional guilty plea to one count of possession of a controlled substance. The Supreme Court affirmed the denial of Appellant’s motion to suppress, holding (1) the initial stop of the vehicle in which Appellant was a passenger was justified because the trooper had reasonable suspicion that the driver was breaking the law; and (2) the subsequent search of Appellant’s jacket was supported by the community caretaker exception to the warrant requirement and thus did not violate the Fourth Amendment. View "Allgier v. State" on Justia Law

After a jury trial, Defendant was convicted of driving while under the influence of methamphetamine and aggravated vehicular homicide based upon recklessness. Defendant appealed, asserting that his constitutional right to a speedy trial was violated because more than 630 days passed between his initial arrest and the case going to trial. The Supreme Court affirmed, holding that under the test set forth in Barker v. Wingo, the delay was not unreasonable, i.e., it did not substantially impair Defendant’s right to a fair trial, and therefore, Defendant’s constitutional right to a speedy trial was not violated. View "Durkee v. State" on Justia Law

After a jury trial, Appellant was convicted of larceny by bailee. The district court sentenced Appellant to eight to ten years in prison but suspended the sentence and placed him on probation. The court also ordered Appellant to pay restitution in the amount of $127,208. The Supreme Court affirmed, holding (1) because he failed to demonstrate prejudice by his counsel’s alleged errors, Appellant could not prevail on his claim that he was denied his right to effective assistance of counsel; and (2) the district court did not abuse its discretion in ordering Appellant to pay restitution in the amount of $127,208. View "Hibsman v. State" on Justia Law

Phillip Sam was charged as an adult with one count of first degree murder and twelve counts of aggravated assault. Sam was sixteen years old at the time of the offense, and several witnesses set to testify at trial were juveniles. After a hearing, the district court entered an order concerning media access during trial that limited the identification of juvenile witnesses who would testify during the trial in open court, concluding that this measure was necessary because some of the juvenile witnesses had been the subject of threats. Petitioner, a newspaper, challenged the prior restraint on publication imposed by the court. The Supreme Court reversed and vacated the district court’s order pertaining to the release of the names of juvenile witnesses, holding that the district court’s order violated the First Amendment because this was not the sort of exceptional case where the district court’s prior restraint on speech survives constitutional scrutiny. View "Cheyenne Newspapers, Inc. v. First Judicial Dist. Court" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree sexual abuse of a minor for sexually assaulting his teenage daughter. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting certain uncharged misconduct at trial; (2) Defendant’s trial counsel did not provide ineffective assistance by not uncovering certain evidence in time to be used at trial; and (3) Defendant’s due process rights were not violated when his appeal was delayed due to the court reporter’s untimely filing of the transcripts from the proceedings below. View "Hodge v. State" on Justia Law

Appellant suffered a workplace injury to his back and applied for permanent partial disability. The Workers’ Compensation Division denied benefits. Appellant requested a contested case hearing. During discovery, the Division served interrogatories and requests for production requesting information regarding Appellant’s work history since the time of his injury. Appellant objected to a number of the interrogatories and requests, asserting his Fifth Amendment right against self-incrimination. The hearing examiner compelled Appellant to answer the discovery, but Appellant continued to invoke his Fifth Amendment right against self-incrimination. The hearing examiner dismissed the contested case as a discovery sanction. The district court affirmed. The Supreme Court reversed, holding (1) Appellant was justified in asserting his Fifth Amendment privilege against self-incrimination because he reasonably believed his answers to the discovery requests could be used in a criminal prosecution against him; and (2) the hearing examiner abused his discretion by acting arbitrarily and capriciously in dismissing the case as a discovery sanction without engaging in the proper balancing of Appellant’s and the Division’s conflicting interests. View "Debyah v. State, ex rel., Dep’t of Workforce Servs." on Justia Law

After a jury trial, Defendant was convicted for aiding and abetting aggravated robbery. Defendant appealed, asserting that the district court denied him the right to due process when it refused to instruct the jury on his defense of duress. The Supreme Court reversed and remanded for a new trial, holding that the district court denied Defendant of his right to a fair trial when it ruled that the duress defense instruction would not be given to the jury after Defendant testified and admitted the elements of the crime, as the facts of the case were sufficient to establish a jury question as to Defendant’s duress defense. View "James v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree sexual abuse of a minor and one count of second-degree sexual abuse of a minor. The Supreme Court affirmed, holding (1) the district court did not err in admitting evidence of Appellant’s prior conviction for sexual assault; (2) the district court did not err in excluding evidence of the victim’s prior sexual conduct; (3) the district court did not err in admitting evidence of domestic abuse; and (4) the prosecutor did not commit misconduct in his statements made during closing argument. View "Carroll v. State" on Justia Law

After a jury trial, Defendant was convicted of aiding and abetting aggravated robbery. Defendant appealed, arguing that the district court denied him the right to due process by declining to instruct the jury on his defense of duress. The Supreme Court reversed and remanded for a new trial, holding that Defendant was denied his right to a fair trial when the district court refused to instruct the jury on Defendant’s defense of duress after Defendant testified and admitted the elements of the crime. Given the evidence presented in this case, Defendant was entitled to a jury determination as to whether he had a reasonable opportunity to avoid the crime. View "James v. State" on Justia Law