Justia Wyoming Supreme Court Opinion Summaries

Blake Brewer was arrested after stealing a sound system and monitor from a Walmart in Gillette, Wyoming, resulting in a loss of $1,887. At the time, Brewer was on parole for a prior fraud-by-check conviction. He entered a plea agreement, pleading guilty to felony theft in exchange for a recommended sentence of 18 to 36 months and agreed to pay restitution. The plea agreement did not specify whether the new sentence would run concurrently or consecutively to any sentence that might be reinstated following a pending parole revocation for his earlier conviction.The District Court of Campbell County accepted Brewer’s guilty plea and imposed the recommended sentence. During the oral pronouncement, the court was silent regarding whether the sentence would run concurrently or consecutively to any reinstated sentence for the prior offense. In its written judgment, however, the court ordered Brewer’s sentence to run consecutive to any other sentence. After a motion from the State, the court issued an order nunc pro tunc to correct the sentence’s duration but retained the consecutive language. Brewer appealed, arguing that the written judgment imposed an illegal sentence because the oral pronouncement did not specify consecutive sentencing and the written order referenced a sentence not yet reinstated by the parole board.The Supreme Court of Wyoming reviewed the case de novo, applying its precedent from Keefe v. State, 2024 WY 93, 555 P.3d 492 (Wyo. 2024). The court held that when a sentencing court is silent on whether a sentence runs concurrently or consecutively, Wyoming law presumes the sentences run consecutively. The written judgment merely confirmed this presumption. The Supreme Court of Wyoming affirmed the district court’s judgment, holding that Brewer’s sentence was not illegal. View "Brewer v. The State of Wyoming" on Justia Law

A police officer in Casper, Wyoming, observed a pickup truck driven by Mark Davis traveling slowly and approaching a stop sign. The officer noticed Davis activated his right turn signal only shortly before stopping at the intersection, estimating the signal was turned on no more than twenty feet before the turn, rather than the statutorily required 100 feet. After stopping Davis, the officer discovered an open beer can and learned Davis’s license was suspended. A subsequent search of the vehicle revealed methamphetamine, marijuana, and drug paraphernalia. Davis was charged with felony possession of methamphetamine and felony possession with intent to deliver.Davis filed a motion to suppress the evidence, arguing the officer lacked reasonable suspicion for the traffic stop because he had activated his turn signal more than 100 feet before the turn. At the suppression hearing in the District Court of Natrona County, the officer testified about his training in estimating distances, and Davis’s expert witness presented calculations based on the dash cam video, but conceded uncertainty about Davis’s speed. The district court reviewed the video and testimony, ultimately finding the officer’s estimate credible and concluding the State met its burden to show reasonable suspicion for the stop. The court denied the motion to suppress, and Davis entered a conditional guilty plea, reserving his right to appeal.On appeal, the Supreme Court of Wyoming reviewed the district court’s denial of the suppression motion, deferring to its factual findings unless clearly erroneous and reviewing constitutional questions de novo. The Supreme Court held that, under the totality of the circumstances, the officer had reasonable suspicion to believe Davis violated the turn signal statute, justifying the stop. The district court’s findings were supported by the record, and the evidence obtained was admissible. The judgment was affirmed. View "Davis v. The State of Wyoming" on Justia Law

Police and medical personnel responded to a motel room in Casper, Wyoming, where they found Chance Arias deceased with injuries consistent with assault and strangulation. Surveillance footage showed James Mavigliano and Amber Cook entering and leaving the room multiple times. Mavigliano was later found nearby with a blue duffle bag containing a broken, bloody lamp, and he possessed the room key and drug paraphernalia. After being advised of his rights, Mavigliano admitted to killing Arias, describing a physical altercation that escalated to him striking Arias with a lamp and strangling him with the lamp’s cord. He acknowledged that Arias did not physically threaten or attack him.The State charged Mavigliano with second-degree murder and possession of a controlled substance. The case was tried before the District Court of Natrona County. At trial, the defense argued self-defense, and the jury was instructed that the State had to prove beyond a reasonable doubt that Mavigliano did not act in self-defense. The jury was also instructed on the requirement of unanimity for its verdict. The verdict form did not include a special interrogatory regarding self-defense, and defense counsel did not request one or object to the form. The jury found Mavigliano guilty of both charges, and he was sentenced accordingly.On appeal, Mavigliano challenged only his second-degree murder conviction, arguing that the district court committed plain error by not including a self-defense interrogatory on the verdict form. The Supreme Court of Wyoming held that there is no clear and unequivocal rule of law requiring a special self-defense interrogatory or unanimity instruction beyond the standard instructions given. The court found no plain error and affirmed the conviction. View "Mavigliano v. The State of Wyoming" on Justia Law

James D. Van Winter moved in with his sister in Wyoming due to financial difficulties. After a family gathering, a dispute arose when Van Winter felt slighted by a guest, leading to a heated argument with his sister. The situation escalated when Van Winter refused to leave, resulting in a physical altercation with his brother-in-law. During the struggle, Van Winter threatened his brother-in-law with a pocketknife, which was later wrestled away, causing a minor injury. Police responded, collected statements and evidence, and Van Winter was arrested. He denied any altercation occurred.The State charged Van Winter with aggravated assault and battery and possession of a deadly weapon with unlawful intent. The District Court of Big Horn County presided over the jury trial, which resulted in convictions on both counts. At sentencing, the court orally imposed an 18–24 month prison term for Count I and a suspended 2–4 year sentence with probation for Count II. However, the written judgment imposed a suspended 3–5 year sentence and specified a three-year probation term. Van Winter appealed, arguing ineffective assistance of counsel for failing to present fingerprint evidence and challenging the discrepancy between the oral and written sentences.The Supreme Court of Wyoming reviewed the case. It held that Van Winter failed to demonstrate prejudice from his counsel’s performance, as the fingerprint evidence would not have changed the trial’s outcome given the consistent witness testimony. Therefore, the district court’s denial of the motion for a new trial was affirmed. However, the Supreme Court found a material conflict between the oral and written sentences for Count II. It vacated the probationary term and remanded the case for the district court to conform the written judgment to the oral pronouncement and to determine the appropriate length of probation. View "Van Winter v. The State of Wyoming" on Justia Law

Joel Lee Wilson was charged with aggravated burglary, robbery, breach of peace, property destruction, and unlawful possession of a controlled substance after forcibly entering the Wolf family’s home in Casper, Wyoming. The home was occupied by Alexander Wolf, a sheriff’s deputy, his wife, and their daughter. Wilson and another man, Daniel Hemmer, knocked and scratched at the door before Wilson broke it open. Upon entry, Wilson confronted the residents and engaged in a violent altercation with Mr. Wolf, while Hemmer interacted with the daughter. The incident ended with both men fleeing after Ms. Wolf intervened with a firearm. Evidence included Facebook messages between Wilson and Hemmer discussing an opportunity to make money and plans for the night, as well as Wilson’s statements to police about collecting a debt.The case was tried before the District Court of Natrona County. At trial, Wilson argued he lacked intent to commit theft, a required element for aggravated burglary and robbery, emphasizing that no property was taken and challenging the admission of the Facebook messages as co-conspirator statements. The district court denied Wilson’s motion for judgment of acquittal, finding sufficient evidence of intent based on the messages, the forceful entry, and the circumstances of the break-in. The jury convicted Wilson on all counts, and he was sentenced to concurrent prison terms.The Supreme Court of Wyoming reviewed whether sufficient evidence supported the jury’s finding of intent to commit theft. Applying the standard of review that favors the State’s evidence and reasonable inferences, the court held that both direct and circumstantial evidence—including the Facebook messages, Wilson’s conduct, and the coordinated entry—supported the jury’s verdict. The court affirmed the convictions, concluding the evidence was sufficient to establish Wilson’s intent to commit theft. View "Wilson v. The State of Wyoming" on Justia Law

In this case, law enforcement officers responded to a domestic disturbance at a residence where they found the defendant holding his pregnant fiancée by the wrists. The officers directed him to remain seated on the kitchen floor during their investigation, which lasted about forty minutes. During this time, the defendant was told he was not under arrest but was not free to leave. He eventually admitted to restraining his fiancée by the chin and neck and taking her to the ground. He was later arrested and charged with several offenses, including aggravated assault and battery.After a preliminary hearing in the Circuit Court, the case was bound over to the District Court of Albany County. The defendant moved to suppress statements made before his formal arrest, arguing they were obtained during a custodial interrogation without Miranda warnings. The State opposed, contending he was not in custody until his formal arrest. The District Court held a hearing, denied the motion to suppress, and accepted the defendant’s conditional guilty plea to aggravated assault, reserving his right to appeal the suppression ruling.On appeal, the Supreme Court of Wyoming reviewed whether the conditional guilty plea was valid under Rule 11(a)(2) of the Wyoming Rules of Criminal Procedure. The Court found that, although the plea was in writing, and both the State and the District Court approved it, the issue reserved for appeal—suppression of the defendant’s statements—was not dispositive. Independent evidence existed that could support conviction even if the statements were suppressed. Because the reserved issue was not dispositive, the conditional plea was invalid.The Supreme Court of Wyoming vacated the judgment of conviction and reversed and remanded the case to the District Court for further proceedings. The main holding is that a conditional guilty plea is invalid if the issue reserved for appeal is not dispositive of the entire case. View "Kotrc v. The State of Wyoming" on Justia Law

A five-year-old child died after being left in the care of the defendant, who was the only adult present at the time. The defendant called 911, reporting the child had fallen down the stairs and was unresponsive. Emergency responders observed significant bruising and signs of oxygen deprivation. The child was transported to a hospital and died the next day. Law enforcement, suspecting abuse, interviewed the defendant at the police station. The defendant was advised of her Miranda rights, acknowledged understanding them, and agreed to speak with officers. Over several hours, during which she was allowed breaks and was not under arrest, the defendant ultimately confessed to beating the child and admitted fabricating the story about a fall.The State charged the defendant with first-degree murder and child abuse. The defendant moved to suppress her confession, arguing it was involuntary due to custodial circumstances, her use of prescription medication, and an invalid Miranda waiver. The District Court of Lincoln County held a suppression hearing without the defendant present, as she was hospitalized, and her counsel consented to proceeding in her absence. The court found the confession voluntary, denied the suppression motion, and admitted the confession at trial. The jury convicted the defendant on both charges.On appeal, the Supreme Court of the State of Wyoming reviewed whether the district court erred in finding the confession voluntary and in conducting the suppression hearing without the defendant present. The Supreme Court held that, under the totality of the circumstances, the confession was voluntary and not the result of coercion or impairment. The court also found that any error in holding the suppression hearing without the defendant was harmless, as there was no reasonable probability her presence would have changed the outcome. The convictions and rulings of the district court were affirmed. View "Marler v. The State of Wyoming" on Justia Law

A nineteen-year-old man was convicted for his involvement in two murders in Wyoming. He was sentenced in 2006 to three consecutive terms of life imprisonment without the possibility of parole, following a jury trial in which he was acquitted of one count of first-degree murder but convicted of conspiracy to commit murder and first-degree murder for the other offenses. The crimes involved the killing of a roommate and a sixteen-year-old, with the defendant playing a significant role in both. At sentencing, the jury declined to impose the death penalty and instead issued mandatory life without parole sentences, as required by Wyoming law at the time.After his direct appeal was denied by the Wyoming Supreme Court, the defendant filed a motion in 2024 to correct his sentences, arguing that mandatory life without parole for “emerging adults” (those aged eighteen to twenty-one) is unconstitutional under both the Wyoming and United States Constitutions. He claimed that new scientific evidence and evolving legal standards, particularly those established in Miller v. Alabama and related U.S. Supreme Court cases, should extend protections against mandatory life without parole to offenders in his age group. The District Court of Campbell County denied his motion, finding that the relevant constitutional protections and precedents did not apply to adults over eighteen.The Supreme Court of Wyoming reviewed the case and affirmed the district court’s decision. The court held that the Wyoming Constitution does not provide broader categorical protections for “emerging adults” than the Eighth Amendment. It concluded that the state’s constitutional provisions on cruel or unusual punishment and on the penal code’s humane principles do not prohibit mandatory life without parole sentences for offenders over eighteen. The court also found no violation of equal protection or entitlement to a new sentencing hearing. The holding clarified that, while Wyoming’s constitution is distinct from the federal constitution, it does not require categorical relief for emerging adults sentenced to life without parole. View "Hicks v. The State of Wyoming" on Justia Law

The case concerns a man who, after being separated from his wife of six months, engaged in repeated and escalating contact with her, including hostile voicemails, text messages, and physically aggressive behavior such as banging on her door and damaging property. After being served with divorce papers, his conduct intensified, including following her, driving by her residence and her mother’s house, and sending threatening messages. One particular text message stated he had “nothing to lose,” would “go back to prison,” and would “die before I go back.” Law enforcement was contacted, and during a recorded conversation with an officer, he again referenced the possibility of returning to prison.The District Court of Sheridan County charged him with felony stalking, based on his conduct and a prior stalking conviction. The prosecution sought to introduce evidence under Wyoming Rule of Evidence 404(b), including the text and recorded statement referencing prison, to show intent, motive, and consciousness of guilt. The district court held a hearing, conducted the required analysis under Gleason v. State, and admitted the text and recorded statement for the stated purposes, while excluding other references to his prior conviction. At trial, the jury found him guilty, and he was sentenced to four to eight years in prison.On appeal, the Supreme Court of Wyoming reviewed whether the district court abused its discretion in admitting the text and recorded statement under W.R.E. 404(b). The court held that the district court properly admitted the evidence, as it was relevant to show intent, motive, and consciousness of guilt, and its probative value was not substantially outweighed by unfair prejudice. The Supreme Court of Wyoming affirmed the conviction. View "Bragdon v. The State of Wyoming" on Justia Law

A defendant was charged with two counts of second-degree sexual abuse of a minor and one count of third-degree sexual abuse of a minor, based on allegations that he engaged in sexual acts with a 15-year-old girl. The alleged conduct included both acts of sexual intrusion and other sexually related behavior. The defendant denied any sexual contact, while the victim and another witness provided testimony about the events. Forensic evidence was inconclusive, and the defendant’s police interview was played for the jury. The jury acquitted the defendant on the two counts of second-degree sexual abuse but convicted him on the third-degree charge.The District Court of Natrona County conducted the trial and provided jury instructions that did not specifically exclude conduct that would qualify as first- or second-degree sexual abuse from the third-degree charge, nor did they specify the factual basis for the third-degree charge. Defense counsel agreed to the instructions as given and specifically requested that the instructions not exclude the conduct alleged in the other counts. After the jury returned its verdict, the defendant appealed, arguing that the jury instructions were erroneous for not excluding first- or second-degree conduct from the third-degree charge and for failing to specify the conduct underlying the third-degree charge.The Supreme Court of Wyoming reviewed the case. It held that the defendant had affirmatively waived any objection to the lack of an instruction excluding first- or second-degree conduct from the third-degree charge by requesting that such language be omitted, invoking the invited error doctrine. The court further held that the district court did not plainly err by failing to specify the factual basis for the third-degree charge in the jury instructions, as there was no clear and unequivocal rule of law requiring such specificity when only a single count was at issue. The Supreme Court of Wyoming affirmed the conviction. View "Townsend v. The State of Wyoming" on Justia Law