Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the orders of the district court denying Appellant's motions to correct an illegal sentence and to withdraw his guilty pleas, holding that the district court did not err.Appellant was serving consecutive life sentences for crimes he committed in Washakie County and Carbon County. In these consolidated appeals, Appellant (1) challenged the Washakie County District Court orders denying his motions to correct an illegal sentence and to withdraw his guilty plea and (2) appealed Carbon County District Court orders imposing sentences consecutive to his Washakie County sentence and denying his Wyo. R. Crim. P. 21 motion. The Supreme Court affirmed the Carbon County sentence and the denial of Appellant's Rule 21 motion, holding (1) the Washakie County District Court lacked jurisdiction to consider Defendant's arguments; (2) the Carbon County sentence did not create an unconstitutional de facto life sentence; and (3) Defendant received effective assistance of counsel at his Carbon County resentencing hearing. View "Sides v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for possession of a controlled substance, holding that the district court did not err in denying Defendant's motion to suppress under the Fourth Amendment to the United States Constitution and Wyo. Const. art. I, 4.A highway patrol trooper stopped Defendant when he twice observed Defendant's vehicle cross the dotted center white line separating the two lanes of traffic. Marijuana was found in a free-air K-9 sniff during the stop. In his motion to suppress, Defendant argued that his failure to maintain a single lane of travel on the two occasions did not create reasonable suspicion justifying the stop of his vehicle. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the district court did not err in concluding that reasonable suspicion supported the initial stop. View "Elmore v. State" on Justia Law

The Supreme Court reversed the decision of the district court denying Defendant's motion to suppress evidence discovered after law enforcement entered Defendant's apartment without a warrant to arrest him after he failed to stop for a traffic violation, holding that the district court erred.In denying Defendant's pretrial motion to suppress the district court concluded that the officers' warrantless entry into Defendant's apartment to arrest him was constitutional under the hot pursuit exception to the Fourth Amendment's warrant requirement. The Supreme Court reversed, holding that, under the circumstances, there was no compelling need requiring immediate police action. View "Fuller v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of two controlled substance charges, holding that the district court did not err in denying Defendant's motion to suppress evidence found during a search of the rental van he was driving.Defendant was charged with four drug-related felonies. Defendant moved to suppress evidence found in the rental van that he was driving, arguing that law enforcement violated his Fourth Amendment rights against unreasonable search and seizure when they detained him for the purpose of having a dog unit arrive of scene. The trial court denied the motion. The Supreme Court affirmed, holding that the district court did not err when it denied Defendant's motion to suppress because law enforcement did not violate Defendant's constitutional rights under the Fourth Amendment. View "Pryce v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony theft, holding that Defendant was not denied his constitutional right to a speedy trial.On October 2, 2017, Defendant was arrested for the theft of a vehicle. While he was detained in Natrona County, Fremont County filed charges against him for the theft of another vehicle. Fremont County filed an information but did not pursue further prosecution on the charges for 481 days. During that time, Defendant was convicted in Natrona County and began serving a sentence. On September 26, 2019, Defendant filed a motion to dismiss the Fremont County charges for lack of a speedy trial. The district court denied the motion. Defendant then entered into a conditional guilty plea agreement. On appeal, Defendant argued that he was denied his constitutional right to a speedy trial. The Supreme Court affirmed, holding that Defendant's constitutional right to a speedy trial was not violated. View "Crebs v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of possession of methamphetamine, possession with intent to deliver methamphetamine, and conspiracy to deliver methamphetamine, holding that the district court did not err in denying Defendant's motion to suppress.After Wyoming Division of Criminal Investigation agents gathered information that Defendant was selling methamphetamine they installed a GPS tracking device on his truck. Wyoming Highway Patrol Troopers initiated a traffic stop of Defendant based on a crack in the front windshield of his truck. After a search, drugs and drug paraphernalia were discovered. Defendant moved to suppress, which the trial court denied. The Supreme Court affirmed, holding that the Troopers had reasonable suspicion to stop the truck for driving with a crack within the front windshield. View "Simmons v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court sentencing Defendant, after a remand, to an aggregate sentence of twelve to fifty years for aggravated robbery, to be served consecutively to a previously imposed sentence for first-degree murder, holding that Defendant's aggregate sentence was constitutional.When Defendant was seventeen years old he and a friend robbed and murdered a hitchhiker. Defendant pled guilty to first degree murder, felony murder, and aggravated robbery. Defendant was convicted to life without parole, which the court later converted to life with the possibility of parole after twenty-five years for murder plus twenty to fifty years for aggravated robbery. Defendant later filed a motion to correct an illegal sentence, arguing that his new aggregate sentence remained a de facto life sentence. The trial court denied the motion, but the Supreme Court remanded. On remand, the trial court resentenced Defendant to twelve to fifty years for aggravated robbery, to be served consecutively to the previously imposed sentence for murder. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it sentenced Defendant for aggravated robbery. View "Davis v. State" on Justia Law

The Supreme Court reversed the judgment of the district court terminating Appellant's parental rights, holding that the district court violated Appellant's due process rights when it determined the best interests of the child without first conducting an evidentiary hearing.The district court found that the Department of Family Services established statutory grounds for termination by clear and convincing evidence. On appeal, Appellant argued that he was not given an opportunity to be heard on the question of whether termination was in the child's best interests. The Supreme Court held (1) neither the termination statutes nor Wyoming case law require a separate hearing to determine the best interests of the child; but (2) Appellant's due process rights were violated when he was deprived of the opportunity to be heard on the question of best interests. View "Niland v. State, ex rel. Department of Family Services" on Justia Law

The Supreme Court dismissed Defendant's appeal from the district court's dismissal of his pro se "Petition for Exoneration Based on Factual Innocence," holding that Defendant did not properly invoke the Supreme Court's jurisdiction.Defendant was convicted of three counts of sexual abuse of a minor in the second degree and one count of sexual abuse of a minor in the third degree. Defendant later filed his petition for exoneration under Wyo. Stat. Ann. 7-12-401 through -407. The district court dismissed the petition without prejudice, determining that the petition was statutorily noncompliant. Defendant appealed. The Supreme Court dismissed the appeal, holding that the dismissal of Defendant's petition was not a final, appealable order, and therefore, this Court lacked jurisdiction over Defendant's appeal. View "Woods v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated assault and battery and mandatory life sentence, holding that the district court did not err in denying Defendant's motion for a new trial based on ineffective assistance of counsel.In charging Defendant, the State sought a habitual criminal sentencing enhancement under Wyo. Stat. Ann. 6-10-201. After a trial, the jury convicted Defendant and found that he qualified for the habitual criminal enhancement under section 6-101-201(b)(ii). The court sentenced Defendant to life imprisonment. Defendant appealed, arguing that his trial counsel did not communicate with him in a manner that enabled him fully to understand he was facing a life sentence, and this deficiency fell below the standard of professional conduct. The Supreme Court affirmed, holding that Defendant failed to establish prejudice. View "Lewis v. State" on Justia Law