Justia Wyoming Supreme Court Opinion Summaries

Appellant Dana Dickey entered a conditional plea to one count of possession of a controlled substance. Dickey reserved the right to appeal the district court's denial of her motion to suppress the methamphetamine found in her purse following a traffic stop, claiming the evidence should have been suppressed as the fruit of a constitutionally infirm detention under the Fourth Amendment. The Supreme Court affirmed, holding that the district court did not err by denying Dickey's motion to suppress where (1) the detention lasted no longer than necessary to effectuate the purpose of the stop, (2) the use of a drug dog during Dickey's lawful detention did not violate any constitutionally protected right, and (3) law enforcement officers had probable cause to search the vehicle. View "Dickey v. State" on Justia Law

Appellant Marshall Washington, while working as a confidential informant for the Division of Criminal Investigation (DCI), was charged with and found guilty of possession of a controlled substance. The district court's judgment and sentence incorrectly stated that Appellant pled guilty to the offenses, and the parties entered a stipulated motion to modify the judgment and sentence to correct the inaccuracy. Washington appealed, arguing that (1) the district court improperly denied discovery of the confidential informant agreement (CI agreement) between him and the DCI as well as the DCI's policy manual; and (2) the matter should be reversed inasmuch as the modified judgment and sentence did not fully comply with Wyo. R. Crim. P. 32. The Supreme Court affirmed the conviction, holding that no reversible error was committed by the trial court because (1) Appellant had access to the CI agreement prior to trial and referred to the document at trial, and denial of Appellant's motion to compel discovery of DCI's policy manual was not an abuse of discretion; and (2) the omissions in the modified judgment and sentence were simply clerical errors that would be corrected on remand to the district court. Remanded. View "Washington v. State" on Justia Law

Francis Weber was severely burned by hot mineral water when he lost consciousness in a steam room in Hot Spring State Park. Weber brought a personal injury action against several defendants, including the State. The district court granted summary judgment in favor of the State, concluding that it was immune from suit pursuant to the Wyoming Governmental Claims Act. The Supreme Court reversed, holding that the State's activities in the park fell within the statutory waiver of immunity for operation and maintenance of a public park as (1) overseeing building construction on leased property and delivery of hot mineral water to lessees are part of the State's operation of the park, and (2) under these circumstances, the State's operation and maintenance of the park included overseeing and/or inspecting its lessee's property. Remanded. View "Weber v. State" on Justia Law

Appellants were the personal representatives of the estates of a husband and wife who were killed in a car accident. The accident was caused by a driver who, prior to the accident, had become intoxicated as a result of consuming alcoholic beverages at a bar and a saloon in Wyoming. Appellants filed a wrongful death and negligence complaint against the owners of the bar and saloon. Appellants also sought a judgment declaring Wyo. Stat. 12-8-301, which provides that no person who legally provides alcohol to another person is liable for damages caused by the intoxication of the other person, was unconstitutional if, as a matter of law, the statute provided immunity to Appellees for their conduct. The district court granted Appellees' motion to dismiss on the ground that the Supreme Court had already found the statute to be constitutional. The Supreme Court affirmed, holding that (1) in the statute, the word "legally" in the phrase "legally provided" does not encompass municipal ordinances, and (2) the statute violates neither the constitutional doctrine of equal protection nor the constitutional prohibition of special laws. View "Baessler v. Freier" on Justia Law

David Baker was convicted on six methamphetamine-related charges. The Supreme Court reversed his convictions on two of the charges and affimed the other four. In these consolidated appeals, Baker (1) challenged the district court's denial of his motion to correct an illegal sentence, and (2) claimed the district court erred when it did not grant him access to e-mail correspondence between the department of corrections and the public defender's office. The Supreme Court affirmed the district court's decisions, holding (1) the district court did not abuse its discretion in denying Baker's motion to correct an illegal sentence, and (2) the district court was correct in observing that Baker's motion for subpoena duces tecum asking for the requested e-mail correspondence was not appropriate in the context of Baker's criminal matter. View "Baker v. State" on Justia Law

Appellant Warren Rathbun was convicted of attempted kidnapping and was sentenced to life in prison. On appeal, the Supreme Court affirmed the conviction and sentence, holding (1) Rathbun's prosecution for attempted kidnapping was not barred by the doctrine of double jeopardy due to his earlier guilty plea to battery because the two crimes each contained elements not contained in the other, and therefore, there was no preclusive effect; (2) the doctrine of res judicata neither barred the refiling of a charge for attempted kidnapping nor a subsequent preliminary hearing on the charge where there was a dismissal of the charge based upon a failure of proof of probable cause at a preliminary hearing; (3) the district court applied the proper penalty range in imposing sentence; and (4) the district court's determination of the penalty range in imposing sentence did not violate Rathbun's right to trial by jury. View "Rathbun v. State" on Justia Law

Christopher Jones pled guilty to a third battery against a household member and was sentenced to a prison term of four or five years. Jones appealed, contending that Wyo. Stat. Ann. 6-2-501(f)(ii), which prescribes the punishment for battery against a household member, was unconstitutionally vague. The Supreme Court affirmed, holding (1) Jones's argument that the statute was ambiguous did not constitute sufficient grounds to invalidate the statute as the mere fact that a statute is ambiguous is not sufficient in itself to violate the constitutional guarantee of due process; (2) the statute was not ambiguous; and (3) because the statute was unambiguous, the rule of lenity did not apply to the case. View "Jones v. State" on Justia Law

After a jury trial, Michael Downing was convicted of unlawful delivery of a controlled substance. Evidence was presented at trial involving an incident wherein a confidential informant (CI), who was working with the state Division of Criminal Investigation (DCI), arranged to purchase morphine pills from Downing. In his appeal, Downing alleged that the district court abused its discretion by denying his pretrial motion seeking discovery of "other buys" in which the CI participated and by excluding at trial evidence of other such buys. The Supreme Court reversed the judgment of conviction, holding that the district court's rulings excluding evidence of the CI's other buys (1) implicated Downing's Sixth Amendment right to confront a witness and (2) were not harmless error beyond a reasonable doubt. Remanded for a new trial. View "Downing v. State" on Justia Law

Respondent Douglas Juarez was stopped by a state trooper for failing to signal his merge from an entrance ramp onto the right lane of an interstate. A subsequent search of Juarez's vehicle yielded nine pounds of marijuana. As a result, Juarez was charged with possession and possession with intent to deliver. Juarez filed a motion to suppress the search and seizure of the marijuana on the grounds that the initial traffic stop was illegal. The district court granted the motion, holding that Juarez was not required to signal his merge because Wyo. Stat. Ann. 31-5-217 did not require motorists to signal when merging onto an interstate roadway. On review, the Supreme Court affirmed, holding that (1) there is no basis in the statute to conclude that a motorist is absolutely required to signal to enter the interstate in every instance; and (2) the district court did not err in granting the motion to suppress. View "State v. Juarez" on Justia Law

K.C., a juvenile, was adjudged delinquent. As part of her disposition, she was allowed to remain in a home environment and placed on supervised probation. After K.C. violated various terms of her probation, her probation was revoked and her disposition changed to placement at a state girls' school for an indefinite period. K.C. appealed. The Supreme Court affirmed, holding (1) the juvenile court did not abuse its discretion in imposing sanctions because placement at the girls' school fell within the statutorily allowable sanctions applicable to K.C. and, thus, the court was not required to provide a written justification for the placement; (2) the juvenile court's consideration of a statement K.C. made that she would not follow the rules of a residential program did not violate K.C.'s right against self-incrimination because the statement was considered only in the dispositional phase of the delinquency proceedings; and (3) there was no violation of Wyo. R. Crim. P. 11 because the rule does not apply to juvenile delinquency proceedings. View "In re K.C." on Justia Law