Justia Wyoming Supreme Court Opinion Summaries

The appellant was convicted of delivery of methamphetamine, second or subsequent offense, and received a suspended sentence with three years of supervised probation. Conditions of probation included obeying Department of Corrections rules and completing any treatment required by his probation officer. After seven months, the State filed a petition to revoke probation, alleging that the appellant left required inpatient treatment at Southwest Counseling Service without completing it. The probation officer’s affidavit detailed that he left treatment against staff advice, had missed office visits, continued to use methamphetamine, and had fled from the probation office, resulting in new criminal charges.The District Court of Carbon County held a probation revocation hearing. Although the appellant initially admitted violating probation, he later claimed his attendance at inpatient treatment was voluntary. The court proceeded to an evidentiary hearing, where the probation officer testified about the appellant’s ongoing drug use, failure to attend required evaluations, and his departure from treatment. The court found by a preponderance of the evidence that he violated probation by not completing required treatment, revoked his probation, and imposed the underlying six to ten-year prison sentence, citing willful violations and unsuitability for continued probation. The appellant appealed, arguing that his due process rights were violated when the State relied on other uncharged probation violations during the dispositional phase.The Supreme Court of Wyoming reviewed the case under the plain error standard because the due process argument was not raised below. The court held there was no due process violation, explaining that written notice is required only for the specific alleged probation violation that forms the basis for revocation, not for other conduct considered during the dispositional phase. The court affirmed the district court’s order revoking probation and imposing the prison sentence, finding no clear or unequivocal rule of law was violated. View "Bustos v. The State of Wyoming" on Justia Law

The case concerns a defendant charged with multiple offenses, including felony conspiracy to commit theft, felony theft, and several misdemeanors. While released on bond for the felony charges, he was arrested and charged with new misdemeanors. He entered into a global plea agreement with the prosecution, agreeing to plead guilty to certain charges in exchange for a recommended deferred sentence on the felony conspiracy count under Wyoming Statute § 7-13-301. However, after a presentence investigation, it was revealed that he had previously received a deferred sentence for a misdemeanor in 1996, but his probation was revoked at that time and he did not receive a discharge and dismissal of the offense.After accepting the guilty pleas but before sentencing, the District Court of Campbell County considered whether the prior 1996 deferred sentence rendered the defendant ineligible for another deferred sentence under Wyoming law. Despite the prosecution’s continued recommendation for deferral, the district court concluded the defendant was not eligible because he had previously received a deferred sentence, and instead imposed a suspended prison sentence. The defendant timely appealed, and the district court stayed imposition of the sentence pending appeal.The Supreme Court of the State of Wyoming reviewed the statutory language of Wyoming Statute § 7-13-301 de novo. The court held that the statute’s plain language makes a defendant ineligible for a deferred sentence only if he has previously been convicted of a felony or has received a “discharge and dismissal” under this or a similar statute in any jurisdiction. Because the defendant had not previously been convicted of a felony and had not received a discharge and dismissal, he remained eligible for a deferred sentence. The court reversed the district court’s sentence and remanded for a new sentencing hearing, clarifying that the district court retains discretion to grant or deny a deferred sentence. View "Maki v. The State of Wyoming" on Justia Law

A high school assistant principal was charged with second-degree sexual assault after engaging in a sexual relationship with a student at the same school. The events began with daily conversations and gifts, followed by increasingly personal text messages. On one occasion, after exchanging messages about meeting up, the student—who was of age but intoxicated—went to the assistant principal’s home, where they engaged in sexual activity. Weeks later, a friend of the student discovered text messages revealing the relationship and reported it to school officials, who contacted law enforcement. After a brief investigation, the assistant principal was arrested and charged under a statute prohibiting sexual contact between school employees and students when the employee is more than four years older.At trial in the District Court of Sheridan County, the State successfully moved to exclude evidence of alleged post-graduation contact between the student and the defendant, specifically claims that the student attended the same gym as the defendant after the school year. The defense argued this evidence could be relevant for impeachment if the student claimed fear or coercion, but the court ruled such evidence irrelevant unless the student’s state of mind was placed at issue, which did not occur at trial. The jury found the defendant guilty, and he was sentenced to prison.On appeal, the Supreme Court of Wyoming reviewed whether the district court abused its discretion by excluding the gym contact evidence and whether admitting brief victim impact testimony constituted plain error. The Supreme Court held that exclusion of the gym evidence was not an abuse of discretion because it was irrelevant to the charged offense, and that any error in admitting victim impact testimony did not result in material prejudice given the overwhelming evidence of guilt. The conviction was affirmed. View "Meyer v. The State of Wyoming" on Justia Law

The case concerns a defendant who, along with a co-conspirator, engaged in a scheme to defraud an elderly victim by misrepresenting their identities and gaining her trust. Over time, the victim was persuaded to provide money through cash, credit card charges, and loans, purportedly to fund a business venture, with promises of profit sharing that never materialized. The co-conspirator also convinced the victim to transfer ownership of her home, claiming it was necessary for maintenance and financial assistance. After discovering unauthorized credit card activity and missing property, the victim reported the matter to authorities, leading to an investigation that uncovered widespread unauthorized transactions and no evidence of a legitimate business.The State of Wyoming charged the defendant with felony theft and conspiracy to commit theft. Pursuant to a plea agreement, the defendant entered a no contest plea to conspiracy, with the theft charge dismissed and restitution to be determined at a hearing in the District Court of Laramie County. At the restitution hearing, the State presented evidence of unauthorized credit card charges and cash advances totaling $92,722.79. The defendant argued that certain credit card charges, particularly those allegedly used for concrete improvements to the victim’s property, should be deducted from restitution because the victim benefited from those expenditures. The district court found insufficient evidence to identify any charges as being for the concrete work or to substantiate the value of such benefit, and therefore declined to deduct those amounts from the restitution award.On appeal, the Supreme Court of the State of Wyoming reviewed whether the district court abused its discretion in denying the requested deduction. The Supreme Court held that the district court did not abuse its discretion, finding no clear evidence that the restitution amount included charges for concrete work that benefited the victim. The order awarding restitution in the amount of $92,722.79 was affirmed. View "Baier v. State" on Justia Law

A 15-year-old boy shot and killed his former girlfriend, a 17-year-old, after sending her harassing and threatening messages. The confrontation occurred at a park following an exchange with the victim’s cousin, which escalated into a plan to fight. The defendant brought his mother’s handgun to the scene and, during the confrontation, shot the victim in the face as she approached him. He was apprehended shortly after the shooting and confessed to law enforcement.The State originally charged the defendant with first-degree murder and misdemeanor stalking. Pursuant to a plea agreement, he pled guilty to second-degree murder and stalking. At sentencing, the prosecutor and defense agreed that an individualized hearing was appropriate, given the defendant’s juvenile status. The prosecution recommended a sentence of 44 to 75 years for the murder conviction, referencing Wyoming’s Bear Cloud line of cases and statutory limits for juvenile offenders. The defense argued that, under Wyoming law and constitutional principles, the maximum allowable sentence for a juvenile convicted of homicide should be 22.5 years to life, or at most a minimum term not exceeding 43 years. The District Court of Natrona County sentenced the defendant to 42 to 75 years for second-degree murder and time served for stalking.On appeal, the Supreme Court of the State of Wyoming reviewed whether (1) Wyoming’s juvenile parole eligibility statute applied, (2) the sentence exceeded statutory limits, and (3) the sentence violated the Wyoming Constitution’s prohibition on cruel or unusual punishment. The Court held that the parole eligibility statute applied only to life sentences, not to terms of years. The sentence fell within statutory limits for second-degree murder. Finally, the Court found the sentence was not “unusual” under the state constitution because there was no consensus among legislatures or courts that such a sentence for a juvenile was unlawful. The Supreme Court affirmed the district court’s judgment. View "Castaner v. The State of Wyoming" on Justia Law

The case involved allegations that a man sexually abused his stepdaughter, JB, when she was a child and later sexually assaulted his biological daughter, FO, when she was a teenager. After JB disclosed the abuse to her probation officer, both she and FO were interviewed by police and provided accounts implicating the defendant in two separate incidents of sexual intrusion. The State charged the defendant with two counts of first-degree sexual abuse of a minor.During trial proceedings in the District Court of Campbell County, the court granted the defendant’s motion to sequester witnesses. However, it was discovered that JB and FO overheard brief portions of a livestream of the trial while waiting to testify, in violation of the sequestration order. The district court questioned the witnesses outside the jury's presence, found no intentional or prejudicial violation, and allowed limited cross-examination on what they overheard, but did not permit questioning about their violation of a court order. The defendant also moved for mistrials based on allegedly improper testimony referencing uncharged conduct under Wyoming Rule of Evidence 404(b), but the court either struck the testimony and instructed the jury to disregard it or found the testimony did not reference uncharged acts, and denied the motions.On appeal, the Supreme Court of Wyoming reviewed whether the district court abused its discretion in limiting the scope of cross-examination and denying mistrials, and whether the defendant’s Confrontation Clause rights were violated. The court held that the district court acted within its discretion, as the violations of the sequestration order were minimal and non-prejudicial, and the limitations on cross-examination did not infringe on the defendant’s confrontation rights. The court also found no abuse of discretion in denying the motions for mistrial and found no cumulative error. The Supreme Court of Wyoming affirmed the convictions. View "O'Dell v. The State of Wyoming" on Justia Law

The case concerns a shooting incident that occurred late at night in Douglas, Wyoming, when the defendant called 911 to report he had shot his cousin, believing the cousin was breaking into his home. Investigation revealed that the cousin was an invited guest, and the defendant gave inconsistent accounts of the events leading up to the shooting, including claims of memory loss and possible intoxication. Both the defendant and the victim had consumed alcohol and the defendant had used THC. The defendant was charged with first-degree murder and pursued defenses including not guilty by reason of mental illness and self-defense. Psychiatric evaluations offered differing opinions on his mental state, one attributing his actions to a PTSD flashback and the other finding his intoxication contributed to his conduct.In the District Court of Converse County, the defendant moved to dismiss the charges, asserting immunity under a Wyoming self-defense statute. The district court excluded testimony from one of the psychiatric experts, finding it irrelevant under the governing statutes, and further determined that the defendant failed to present competent evidence sufficient to establish a prima facie case for self-defense immunity. The case proceeded to a jury trial, where the defendant was convicted of second-degree murder and sentenced accordingly.Upon appeal, the Supreme Court of the State of Wyoming affirmed the district court’s decisions. It held that the lower court properly excluded the psychiatric testimony as irrelevant to the self-defense immunity issue. The Supreme Court found the defendant failed to present admissible, competent evidence to support a prima facie self-defense claim. It declined to review the jury instruction challenge due to invited error, as the defendant proposed the instruction in question. Finally, the Supreme Court concluded that sufficient evidence supported the conviction for second-degree murder and affirmed the judgment. View "Helms v. The State of Wyoming" on Justia Law

Police officers in Casper, Wyoming stopped a woman driving with her infant child and an adult passenger, believing the vehicle’s cracked windshield violated traffic laws and suspecting the passenger had active warrants. After arresting the passenger and searching the vehicle with the driver’s consent, officers discovered suspected methamphetamine in the driver’s backpack. The driver admitted to recent drug use and consented to a search of her apartment, where more methamphetamine was found. She was charged with felony child endangerment and misdemeanor possession, accused of allowing her child to remain in places where she knew methamphetamine was present.The driver filed a motion in the District Court of Natrona County to suppress evidence from the vehicle and apartment searches, arguing the traffic stop was unjustified and her consent and statements were involuntary. The district court denied the motion, finding the stop was lawful, Miranda warnings were not required, and her statements were voluntary. She then entered a conditional guilty plea to child endangerment, reserving the right to appeal the suppression ruling, and was sentenced to probation under a plea agreement. The misdemeanor possession charge was dismissed.On appeal, the Supreme Court of Wyoming reviewed the validity of the conditional guilty plea under Wyoming Rule of Criminal Procedure 11(a)(2). The Court found that while the plea satisfied the requirements for written reservation, State consent, and district court approval, it failed because not all issues reserved for appeal were dispositive. Only the challenge to the legality of the initial stop would end the case if resolved in appellant’s favor, while the other issues would not. The Supreme Court of Wyoming held the conditional plea was invalid and vacated the judgment and sentence, remanding for further proceedings. View "Stone v. State of Wyoming" on Justia Law

Dixon Dean Cole was originally charged in 1996 with multiple counts of sexual assault and immoral or indecent acts with minors. Through a plea agreement, he pled guilty to one count of sexual assault in the fourth degree (a misdemeanor) and one count of immoral or indecent acts with a minor (a felony). He received suspended sentences and probation, and after fulfilling all court-ordered requirements, he was discharged from probation in 2001. Both convictions required him to register as a sex offender due to the ages of the victims.Years later, Cole was charged with failing to register as a sex offender. While those charges were pending, he sought expungement of both convictions and requested to be relieved of his registration duty. The District Court of Sweetwater County expunged his misdemeanor conviction (applying the felony expungement statute in error) and terminated his duty to register for the felony conviction. The State objected, arguing Cole was statutorily ineligible for expungement due to his registration status.On appeal, the Supreme Court of Wyoming determined that although the district court used the incorrect statute for the misdemeanor expungement, Cole was otherwise eligible under the proper statute, and the results would have been the same. The Court declined to consider arguments about whether Cole posed a danger to society, as these were not properly raised in the district court. Regarding the termination of the sex offender registration requirement, the Supreme Court found no abuse of discretion, noting Cole met all statutory prerequisites and that a pending failure-to-register charge did not automatically bar relief.The Supreme Court of Wyoming affirmed both the expungement of the misdemeanor conviction and the order terminating Cole’s duty to register as a sex offender. View "State v. Cole" on Justia Law

The case concerns an altercation in Sheridan, Wyoming, during which Cody McCalla and his friend encountered Patrick Mudd and Mudd's girlfriend over a parking dispute. After a verbal confrontation, McCalla and his friend moved their vehicle and proceeded toward the fairgrounds. Mudd stood on the sidewalk, and a second confrontation ensued between McCalla and Mudd, escalating into physical violence. After several exchanges, McCalla ultimately punched Mudd, causing him to fall, hit his head, and later die from his injuries. McCalla was charged with involuntary manslaughter.The District Court of Sheridan County reviewed several pretrial motions. McCalla moved to compel production of unredacted law enforcement reports, which the district court denied, finding the redacted portions exempt from disclosure under Wyoming Rule of Criminal Procedure 16. McCalla also moved to dismiss the charge, claiming immunity from prosecution under Wyoming Statute § 6-2-602(f) on grounds of self-defense. The district court held an evidentiary hearing, requiring McCalla to proceed first, as his motion alone did not establish a prima facie case. After testimony, the district court found McCalla met his prima facie burden, but the State proved by a preponderance of evidence that McCalla was the initial aggressor in the second altercation and did not use reasonable defensive force, denying immunity.The Supreme Court of Wyoming reviewed the appeal. It held the district court did not err in requiring McCalla to proceed first at the evidentiary hearing, found no error in the district court’s determination that McCalla was the initial aggressor and thus not entitled to self-defense immunity under Wyoming Statute § 6-2-602(f), and declined to address the discovery issue, as it was not properly preserved for appeal. The Supreme Court affirmed the district court’s rulings. View "Mccalla v. The State of Wyoming" on Justia Law