Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Appellant Charles Jones was convicted of aggravated robbery and first-degree murder. Jones appealed, arguing that the trial judge erroneously instructed the jury, that there was insufficient evidence to convict him, and that the prosecutor committed cumulative error. The Supreme Court affirmed, holding (1) the trial judge's failure to give an intent instruction was harmless, as there was no prejudice to Jones; (2) the jury had sufficient evidence to convict Jones of robbery; and (3) Jones was not denied his right to a fair trial due to the cumulative effect of any alleged prosecutorial misconduct that may have occurred. View "Jones v. State" on Justia Law

Black Diamond Energy Partners (BDE Partners) were Nevada limited partnerships which owned interests in coal bed methane wells located in Wyoming. Black Diamond Energy, Inc. (BDE Inc.) was a Wyoming corporation and the managing general partner of several of the BDE Partners. Black Diamond Energy, Inc. of Delaware (BDE Del) was a Delaware corporation and the managing general partner of two of the BDE Partners. BDE Inc. and BDE Del were wholly owned subsidiaries of Koval Resources, LLC, a Nevada limited liability company. Koval entered in a loan agreement in Pennsylvania with S&T Bank, a regional state bank with offices only in Pennsylvania. Koval ultimately defaulted on the loan. BDE Partners filed a complaint in Wyoming against S&T alleging negligence, breach of fiduciary duty, breach of the implied covenant of good faith and fair dealing, and other claims. The district court dismissed the complaint for lack of personal jurisdiction. The Supreme Court reversed, holding that BDE Partners presented sufficient undisputed evidence that S&T's activities in Wyoming were such that, as a matter of law, Wyoming courts had personal jurisdiction to decide their claims. View "Black Diamond Energy Partners Ltd. v. S&T Bank" on Justia Law

After entering a conditional plea to one count of felony child abuse, Roman Vance reserved his right to challenge the denial of his motion to dismiss, which was premised on grounds of constitutional speedy trial. On appeal, Vance claimed that a six and one-half year delay between charging and arrest raised a presumption of prejudice that the State did not persuasively rebut. The Supreme Court agreed and reversed, holding that the district court erred in denying Vance's motion to dismiss based upon a violation of his constitutional speedy trial right, as the court overlooked the question of presumptive prejudice and because no evidence was offered by the prosecution to rebut the presumption of prejudice afforded to Vance. View "Vance v. State" on Justia Law

After a jury trial, Appellant Francis Guerrero was convicted of felony larceny. The district court sentenced Appellant to three to five years of imprisonment. Appellant appealed, claiming the district court erroneously instructed the jury on the elements of larceny and that the evidence presented at trial was insufficient to support his conviction. The Supreme Court agreed with Appellant's second claim and reversed, holding that the evidence was insufficient to show that Appellant's activities constituted a taking, one of the elements of larceny, as opposed to a conversion. Consequently, the Court found that Appellant was entitled to an acquittal on the charge of felony larceny. View "Guerrero v. State" on Justia Law

Following a jury trial, Timothy Kramer was convicted of attempted first-degree murder. The Supreme Court affirmed, holding (1) the trial court did not plainly err in instructing the jury on the elements of first-degree murder; (2) Kramer's trial attorneys were not ineffective by not objecting to the jury instructions, and counsel's investigation into the timeline of events was sufficient; and (3) the trial court did not err or violate Kramer's confrontation right when it allowed one of the main witnesses in the trial to testify via video conference, as, under the circumstances, presentation of this testimony in that manner was necessary to further an important public policy, and the reliability of the testimony was otherwise assured. View "Kramer v. State" on Justia Law

Defendant Christopher Counts was convicted of aggravated burglary and kidnapping. On appeal, the Supreme Court affirmed, holding (1) any error by the district court in admitting redacted documents and recordings into evidence was harmless; (2) the district court erred by limiting Defendant's cross-examination of the victim, but the error was harmless; (3) the district court did not abuse its discretion in denying a motion for a bill of particulars; (4) the district court properly instructed the jury; (5) the verdict was consistent; and (6) there was sufficient evidence to support the verdict on the charges of kidnapping and aggravated burglary. View "Counts v. State" on Justia Law

Alfred Baldes, a certified nursing assistant, was convicted of two counts of third-degree sexual assault after giving a young man who suffered from muscular dystrophy a sponge bath. The Supreme Court affirmed, holding (1) the evidence presented at trial was sufficient to sustain Baldes' conviction, and specifically, there was sufficient evidence for a reasonable juror to conclude that Baldes was in a position of authority and that sexual contact occurred, respectively; and (2) the trial court did not err when, following a Gleason analysis, it allowed the introduction of Wyo. R. Evid. 404(b) evidence, specifically the testimony of another client of Baldes'. View "Baldes v. State" on Justia Law

After being separately cited and arrested for driving while under the influence of alcohol (DWUI), Ricky Miller and Christopher Gonzalez (Petitioners) petitioned the district court for review of agency inaction by the Wyoming Department of Health (WDOH). Miller and Gonzalez requested that the district court require the WDOH to retroactively decertify the chemical test operators who had performed chemical tests of Petitioners' breath to determine the quantity of alcohol in their respective bodies. The district court dismissed the petition on the grounds that Petitioners lacked standing to bring the action and that the matter was not ripe for review. The Supreme Court affirmed, holding that Petitioners did not satisfy the three elements of standing as set forth in Lujan v. Defenders of Wildlife, and therefore, the district court did not err in dismissing Petitioners' petition for review for lack of standing. View "Miller v. Dep't of Health" on Justia Law

Pursuant to a plea agreement, Christina Clark pled guilty to two counts of third degree sexual abuse of a minor. The district court sentenced her to two concurrent terms of six to ten years in prison. Clark appealed from the judgment and sentence, claiming her guilty pleas were not voluntary and she was entitled to a new sentencing hearing because the district court failed to mention probation in the written judgment and sentence in accordance with Wyo. R. Crim. P. 32. The Supreme Court affirmed but remanded for entry of an amended judgment, holding (1) Clark made a voluntary and informed choice to plead guilty; and (2) the district court in this case clearly considered probation before imposing a prison sentence. Remanded to the district court with directions to enter an amended sentence reflecting that the court considered probation in accordance with Rule 32. View "Clark v. State" on Justia Law

Dennis Poitra and two other assailants were involved in the armed robbery of a residence that ended in the killing of a seventy-six-year-old. A jury convicted Poitra of felony murder, aggravated burglary, and conspiracy to commit burglary. The Supreme Court affirmed, holding (1) the trial court did not err in denying Poitra's right to present the defense of involuntary intoxication and in refusing to instruct the jury on the defense of involuntary intoxication; (2) the trial court did not abuse its discretion in denying Poitra's motion to change venue and did not violate his right to a trial by a fair and impartial jury in doing so; and (3) the district court did not abuse its discretion in sentencing Poitra to life imprisonment without the possibility of parole. View "Poitra v. State " on Justia Law