Justia Wyoming Supreme Court Opinion Summaries

Defendant entered guilty pleas to aggravated burglary, first-degree murder, and conspiracy to commit aggravated burglary. Defendant was sentenced to life imprisonment on the first-degree murder conviction. At the time of the murder, Defendant was a juvenile. The Supreme Court affirmed, holding that Defendant's sentence of life imprisonment for first-degree murder, mandated by Wyo. Stat. 6-2-101(b), was constitutional. After that decision, the U.S. Supreme Court issued Miller v. Alabama, where it held that the Eighth Amendment forbids a sentencing scheme that mandates life in prison without the possibility of parole for juvenile offenders. Based on Miller, Bear Cloud petitioned for certiorari to the U.S. Supreme Court. The U.S. Supreme Court granted the petition, vacated the judgment in Bear Cloud I and remanded the case to the Wyoming Supreme Court. On remand, the Court held that, in light of the Miller decision, Bear Cloud's sentence for his first-degree murder conviction violated the Eighth Amendment and related U.S. Supreme Court case law. Remanded with instructions to resentence Bear Cloud on the first-degree murder conviction. View "Bear Cloud v. State" on Justia Law

After RB, a middle-aged man, was emergently detained as a suicide risk at West Park Hospital, the district court involuntarily hospitalized RB at the Wyoming State Hospital, where he was detoxified of opiates and other controlled substances and eventually stabilized on psychotropic medications. The State Hospital then notified the district court and the county attorney that it intended to discharge RB. The county attorney filed an objection with the district court, claiming a right to a hearing on the merits of the State Hospital's decision. The district court concluded that the county had no standing to object to RB's discharge. The Supreme Court affirmed, holding that the involuntary hospitalization statutes do not provide authority for a county attorney to object to the proposed discharge of a patient from involuntary civil commitment. View "State v. Wyo. State Hosp." on Justia Law

Plaintiff, the secretary of state, filed a declaratory judgment action challenging the constitutionality of Wyoming's term limit statute. Plaintiff contended that the statute was prevented from exercising his constitutional right to seek a third term as secretary of state. The State retorted that Plaintiff's complaint did not present a justiciable controversy and, in any event, the statute was constitutional. The Supreme Court accepted certification of the issues from the district court and held (1) Plaintiff's complaint satisfied the four elements necessary to establish a justiciable controversy; and (2) the statute limiting the term limit for statewide elected officials is unconstitutional with respect to the offices of secretary of state, auditor, treasurer, and superintendent of public instruction, and the qualifications for those offices provided by the Wyoming Constitution are exclusive. View "Maxfield v. State" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to obtain property by false pretenses and was sentenced to a prison term of eight to ten years. Defendant appealed, challenging the admission of uncharged misconduct evidence and alleging prosecutorial misconduct in the State's sentencing recommendation. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in determining that the probative value of the uncharged misconduct evidence was not outweighed by its potential for unfair prejudice and thus in admitting the evidence; and (2) the State did not commit prosecutorial misconduct in its sentencing memorandum to the district court, and thus the district court entered a sentence permitted by law. View "Magnus v. State" on Justia Law

The district court appointed Attorney to represent an indigent parent in a termination of parental rights action filed by the Wyoming Department of Family Services (DFS). State law required DFS to pay for the costs of the action, including the attorney's fee for the indigent parent. After a jury trial, the parent's parental rights were terminated. Several months later, Attorney filed a motion for an order approving payment of his attorney's fees in his representation of the parent. The district court awarded Attorney a fifty percent reduction from the fees sought in the motion. The Supreme Court affirmed the fee reduction, holding that the district court did not abuse its discretion by reducing Attorney's fee application by fifty percent. View "Tolin v. State" on Justia Law

After a jury trial, Defendant was convicted of taking a controlled substance into a jail. Defendant appealed, contending (1) the district court erred by seating an unqualified juror; and (2) the court erred in sentencing by not giving him full credit for time spent in presentence incarceration. The Supreme Court affirmed the conviction and sentence, holding that the district court (1) did not err in seating the jury, as the disputed juror was a resident of the relevant county for the required time period preceding the jury selection and return, and therefore, the juror was qualified; and (2) properly credited Defendant for presentence confinement from the time when Defendant's first sentence expired to the time when the court entered sentence on Defendant's drug-related conviction. View "Lake v. State" on Justia Law

Appellant was convicted of felony larceny after taking a pickup truck without the owner's permission. After the verdict was accepted, Appellant moved for a new trial, alleging that jurors or potential jurors overheard conversations between the State's witnesses, and that the information they overheard tainted and prejudiced them. The district court denied the motion, finding that Appellant had waived his right to ask for a new trial by failing to bring the issue to the court's attention during trial. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in denying Appellant's motion for a new trial on the ground that he waived his challenge by failing to raise it during trial; and (2) there was sufficient evidence of Appellant's intent to deprive the owner of the truck of that property as required for a conviction of larceny. View "Pena v. State" on Justia Law

Defendant pled no contest to first-degree sexual abuse of a minor. The district court imposed a penitentiary sentence of not less than fifteen nor more than twenty years. Approximately one year after his conviction, Defendant filed a pro se motion for a reduction of his sentence, asserting that a sentence reduction was warranted by his good behavior in prison and by his inability to assist his wife, who suffered from multiple sclerosis, and his daughter. The district court denied the motion, concluding that the sentence Defendant received as a result of his plea deal was exceptionally reasonable under the circumstances. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the sentence reduction motion, where it was reasonable for the district court to conclude that Defendant's attendance of a common course of first-year prison programs was only a relatively small first step toward rehabilitation. View "Conkle v. State" on Justia Law

Defendant was charged with a felony DUI, his fourth, after a law enforcement officer was informed that Defendant had been drinking and was about to drive his vehicle. Defendant filed a motion to suppress, claiming that his stop and arrest were unconstitutional because the officer's actions were based upon a tip from an unidentified informant. The motion was denied, and Defendant was found guilty after a jury trial. The Supreme Court affirmed the district court's judgment, holding (1) the district court properly denied Defendant's motion to suppress, where the totality of the circumstances in this case created reasonable suspicion that Defendant was committing a crime and because the informant was not anonymous; and (2) there was substantial evidence for a jury to convict Defendant at trial. View "Venegas v. State" on Justia Law

After a jury trial, Defendant was convicted of sexual exploitation of a child. Defendant appealed, contending (1) the district court erred in denying his motion for judgment of acquittal for lack of sufficient evidence, and (2) the jury's verdict was tainted by prosecutorial misconduct. The Supreme Court affirmed Defendant's conviction, holding (1) sufficient evidence existed for the case to be submitted to the jury, and therefore, the district court correctly denied Defendant's motion for judgment of acquittal and allowed the jury to ultimately determine whether the State had proved his guilt beyond a reasonable doubt; and (2) the prosecutor did not engage in impermissible misconduct. View "Craft v. State" on Justia Law