Justia Wyoming Supreme Court Opinion Summaries

Appellant Leah Benjamin was convicted of second-degree murder for the shooting death of her estranged husband. On appeal, the Supreme Court affirmed, holding (1) the trial court did not abuse its discretion by denying Appellant's request to remove a juror who was related to one of the State's listed witnesses; (2) the trial court did not err in refusing Appellant's proposed jury instructions; (3) the trial court did not err in denying Appellant's post-trial motion for judgment of acquittal; and (4) Appellant failed to demonstrate that the prosecutor engaged in prejudicial misconduct during the prosecutor's opening statement, voir dire, or the prosecutor's closing argument. View "Benjamin v. State" on Justia Law

Appellant Mark Orchard was arrested for driving while under the influence of alcohol. As a result, the Wyoming Department of Transportation (DOT) advised Appellant that it was suspending his driver's license. Appellant contested the suspension before the Office of Administrative Hearings (OAH), and the OAH upheld the suspension. The district court affirmed. Appellant appealed, contending that the police officer who arrested him lacked reasonable suspicion to initiate the traffic stop. The Supreme Court affirmed, holding that the DOT's certified record, which included the arresting officer's signed statement, constituted relevant evidence that a reasonable mind might accept as adequate to support the determination that the arrested office had probable cause or reasonable suspicion to initiate a traffic stop of Appellant's vehicle. View "Orchard v. State Dep't of Transp." on Justia Law

Appellant Joshua Lascano was convicted of one count of burglary and sentenced to six to ten years. During trial, in order to have evidence indicating that Lascano was a member of a gang admitted, the State asserted that the burglary was an act of gang retaliation and that, but for the gang affiliations, the burglary would not have occurred. Lascano appealed, arguing that the prosecutor committed misconduct by misrepresenting the relevance of the gang evidence. The Supreme Court affirmed, holding (1) no prosecutorial misconduct occurred when gang evidence was admitted in this case, and (2) the district court did not abuse its discretion in so admitting the gang evidence. View "Lascano v. State" on Justia Law

A state trooper stopped William Tiernan on suspicion of driving while impaired after he observed Tiernan's vehicle cross the center line and fog line a couple of times. The trooper conducted field sobriety tests and arrested Tiernan for driving under the influence of alcohol. Tiernan refused to submit to chemical testing. The Department of Transportation (DOT) subsequently suspended Tiernan's driver's license. The Office of Administrative Hearings (OAH) upheld the suspension. The district court affirmed. Tiernan appealed, contending that the trooper failed to present sufficient facts to support the stop for a lane violation. The Supreme Court affirmed, holding that substantial evidence supported the agency's decision. View "Tiernan v. State" on Justia Law

Appellant Randal Craft entered a conditional guilty plea to felony possession of a controlled substance and reserved the right to appeal whether he entered a valid waiver of counsel in a prior conviction that was used to enhance the present charge to a felony. The Supreme Court affirmed, holding that the district court did not err in finding Appellant's waiver of counsel in the proceeding at issue was knowing and intelligent where the advisements given in the proceeding complied with the requirements of Wyo. R. Crim. P. 11, and there was no indication in the record that Appellent did not understand those advisements, including the advisement that he had a right to an attorney. View "Craft v. State" on Justia Law

In 1999, James Graham was convicted on four counts of obtaining property by false pretenses. Graham's appeal challenged the amount of restitution ordered as part of his sentence. The Supreme Court affirmed in part and reversed in part. In 2010, Graham filed a motion to correct an illegal sentence. The district court ruled that Graham's sentence was not illegal and denied the motion. The Supreme Court affirmed, holding (1) Graham's appeal was barred under the doctrine of res judicata because he could have raised the majority of his issues in his initial appeal and did not suggest any good cause for failing to do so; (2) because res judicata barred his claims that the underlying sentence was illegal, there was no foundation for his challenge to the subsequent revocation of his probation; and (3) the Court was not compelled to consider Graham's claims in the interests of justice, largely because his claims were without merit. View "Graham v. State" on Justia Law

Appellant Christopher Harrell was convicted of rape, kidnapping, and assault. Appellant appealed, arguing that the district court abused its discretion when it did not allow him to introduce evidence that he had been acquitted of a previous battery charge and that his Sixth Amendment right to compulsory process was violated because he was deprived of testimony that was vital, material, and relevant to his defense. The Supreme Court affirmed, holding that Appellant's arguments were not persuasive and that Appellant did not demonstrate that he suffered prejudice from the district court's refusal to allow him to introduce testimony about his previous acquittal for battery. View "Harrell v. State" on Justia Law

Petitioner Bobby Jenkins was charged with misdemeanor animal cruelty after a horse he owned was discovered in dire physical condition. A jury convicted him of the charges. The district court affirmed. Petitioner petitioned the Supreme Court for a writ of review, alleging ineffective assistance of counsel. The Supreme Court affirmed, holding that Petitioner failed to show that he was materially prejudiced by trial counsel's failure to (1) object to testimony and argument regarding the arrest and incarceration of both Petitioner and his brother, (2) object to the prosecutor's improper questioning of a witness about the credibility of another witness, or (3) object to the prosecutor's question relating to allegedly irrelevant testimony about the condition of other horses and Petitioner's speeding ticket. View "Jenkins v. State" on Justia Law

Appellant Thomas Stastny was convicted of sexual abuse of a minor and attempted sexual abuse of a minor. On appeal, Appellant challenged the district court's admission of evidence of a prior conviction, accused the prosecutor of committing misconduct during closing argument, and alleged that these cumulative errors required reversal of his convictions. The Supreme Court affirmed, holding (1) the doctrine of invited error barred Appellant from raising in his appeal issues concerning the admission of evidence of his prior conviction, (2) plain error did not occur as a result of prosecutorial misconduct during closing argument, and (3) as there was no error, the doctrine of cumulative error did not require reversal of Appellant's convictions. View "Stastny v. State" on Justia Law

Craig Winstead pled guilty to three counts of third degree sexual assault, and the district court sentenced him to ten to fifteen years on each count with the sentence on the first count to be served first and the sentences on the second and third counts to be served consecutively to the first sentence and concurrently with each other. Winstead filed a motion to correct on illegal sentence, claiming his sentences should have merged and asking the court to order that he serve his sentences concurrently. The district court denied the motion. The Supreme Court affirmed, holding that Winstead's claim was barred by the doctrine of res judicata because Winstead could have raised the issue during the sentencing hearing, on direct appeal, or when he filed a motion for judgment and sentence nunc pro tunc and failed to do so. View "Winstead v. State" on Justia Law