Justia Wyoming Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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In the State of Wyoming, Jonathon Tyson Blair, representing himself, appealed the denial of his motion for sentence reduction by the District Court of Sweetwater County. Blair had been sentenced to a term of eight to ten years and requested a reduction to a term of five to ten years. He argued that he had taken steps to improve himself while incarcerated and that he needed the sentence reduction to prevent his welding certification from expiring, so he could financially support his family upon release.The Supreme Court of Wyoming affirmed the decision of the lower court, stating that the denial of the motion for sentence reduction did not constitute an abuse of discretion. The court highlighted that the sentencing judge is in the best position to determine if a sentence modification is appropriate and can accept or reject information submitted in support of a sentence reduction at their discretion. The court found that there was a rational basis from which the lower court could draw its conclusion and that the original sentence imposed on Blair remained appropriate. The court also dismissed Blair's allegations of bias and illegal sentencing, stating that these issues were not raised in his motion for sentence reduction and could not be raised for the first time on appeal. Furthermore, the court discarded Blair's claim that his pre-sentencing time served was not credited to his sentence, stating that this was a matter for relief under a different rule and that the issue had already been addressed and rejected in prior proceedings. View "Blair v. The State of Wyoming" on Justia Law

Posted in: Criminal Law
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The case revolves around the defendant, Daniel A. Chace, who appealed the denial of his motion to suppress evidence obtained through a search warrant executed after 10:00 p.m. The incident began when law enforcement stopped a vehicle for a traffic violation, driven by Mr. Chace’s brother. A search of the vehicle following a K-9 unit’s drug alert resulted in the discovery of methamphetamine and paraphernalia. That evening, the officers requested a search warrant for the driver's residence, where Mr. Chace was temporarily staying. The search warrant was executed shortly after 10:00 p.m., leading to the discovery of more drugs and paraphernalia in Mr. Chace's backpack.Mr. Chace argued that the evidence should be suppressed because the search of the residence violated Rule 41 of Wyoming's Rules of Criminal Procedure, which restricts the execution of search warrants to between 6:00 a.m. and 10:00 p.m., unless express authorization for a different time is provided based on good cause. The Supreme Court of Wyoming, however, affirmed the district court's decision, concluding that the nighttime search did not prejudice Mr. Chace and that law enforcement did not intentionally and deliberately disregard the limits in Rule 41(e)(1). The court maintained that a violation of Rule 41 alone does not necessarily equate to a Fourth Amendment violation and does not always invoke the application of the exclusionary rule. View "Chace v. The State of Wyoming" on Justia Law

Posted in: Criminal Law
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The Supreme Court of Wyoming upheld the conviction of Charles Anthony "Tony" Santistevan for multiple counts of sexual assault and one count of voyeurism. The court found that the district court did not abuse its discretion when it allowed the state to introduce evidence that Santistevan's sexual relationship with the victim, R.S., began when she was a minor. This evidence was introduced under the Wyoming Rules of Evidence (W.R.E.) 404(b), which allows evidence of other crimes, wrongs, or acts for certain purposes, such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident. Santistevan argued that the introduction of this evidence was an abuse of the district court's discretion, but the Supreme Court disagreed. It held that the evidence was relevant and admissible under W.R.E. 404(b) to show an ongoing scheme or plan and to demonstrate Santistevan's course of conduct, and to provide a complete story to the jury about the relationship between Santistevan and R.S., thereby aiding in determining the issue of consent in the sexual assault charges. View "Charles A. Santistevan v. The State of Wyoming" on Justia Law

Posted in: Criminal Law
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In this case, Shaun T. Kobielusz appealed his convictions of three counts of voyeurism. Kobielusz contended that there was insufficient evidence of the element of “looking” for the jury to convict him of voyeurism, that the jury instruction given on the elements of voyeurism was improper, and that the district court erred when it denied his motion to suppress videos on a memory card given to law enforcement by his wife. The Supreme Court of Wyoming disagreed with Kobielusz's claims. They determined that the voyeurism statute does not require proof of “looking” at the captured images for a conviction. They also found that the jury instruction did not violate a clear and unequivocal rule of law. Lastly, they affirmed the district court's decision to deny Kobielusz's motion to suppress the videos, concluding that his wife had common authority over the memory cards and had the right to consent to their search. Therefore, the court affirmed Kobielusz's conviction. View "Kobielusz v. Wyoming" on Justia Law

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The case revolves around Leopoldo Alvarado, who sought to terminate his duty to register as a sex offender after having registered for at least ten years, pursuant to Wyo. Stat. Ann. § 7-19-304 of the Wyoming Sex Offender Registration Act. The District Court denied his petition on the grounds that the time he spent on probation did not count toward the ten-year statutory prerequisite.However, the Supreme Court of the State of Wyoming disagreed and reversed the decision of the District Court. The Supreme Court found that the clear and unambiguous language of Wyo. Stat. Ann. § 7-19-304 does not require probation to be completed before the ten-year registration period begins to run. The court ruled that probation is not listed as a tolling event, and the court will not read words into a statute when the legislature has chosen not to include them.The Supreme Court stated that the District Court should have considered whether Mr. Alvarado should be relieved of the duty to continue registration after demonstrating he had maintained a clean record by meeting all four conditions during the ten-year registration period. These conditions included having no conviction of any offense for which imprisonment for more than one year may be imposed, having no conviction of any sex offense, successfully completing any periods of supervised release, probation, and parole, and successfully completing any sex offender treatment previously ordered by the trial court or his probation or parole agent. The case was remanded for further consideration. View "Alvarado v. State" on Justia Law

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In Wyoming, Remi Larsen was facing a misdemeanor charge for possession of a controlled substance. Larsen moved to suppress evidence obtained during a warrantless search of her apartment. The trial court granted Larsen's motion, ruling that she did not voluntarily consent to the search. The State appealed this decision, resulting in the district court reversing the trial court's order. On further appeal, the Supreme Court of Wyoming held that the district court abused its discretion when it initially granted the State's petition for an interlocutory writ of review. The Supreme Court explained that the district court should only grant such a review in "rare and unusual" cases that present questions of first impression, constitutional magnitude, and great public import. The court found that Larsen's case did not meet these criteria. The court's order was reversed, and the lower court was directed to reinstate the original suppression order. View "Larsen v. State" on Justia Law

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In this case, appellant Ismael Ruiz sought to appeal the dismissal of his motion for a sentence reduction by the District Court of Sweetwater County, Wyoming, arguing that the court had erred in ruling it did not have jurisdiction over his motion. The Supreme Court, State of Wyoming found that Ruiz had filed his motion for sentence reduction beyond the one-year deadline stipulated by Wyoming Rule of Criminal Procedure (W.R.Cr.P.) 35(b). Therefore, the District Court correctly concluded it lacked jurisdiction over the motion. As a result, the Supreme Court, State of Wyoming also lacked jurisdiction to consider the appeal and dismissed it. The details of the case involve Ruiz's 2018 conviction for aggravated assault and battery, for which he was sentenced to seven to ten years in prison but placed on supervised probation for five years. After violating his probation in 2019, the original prison sentence was imposed. Ruiz attempted multiple times to have his sentence reduced or his conviction overturned, with all motions being dismissed by the District Court due to untimeliness or lack of jurisdiction. View "Ruiz v. The State of Wyoming" on Justia Law

Posted in: Criminal Law
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In a case before the Supreme Court of the State of Wyoming, appellant Darrell Leonardo Alexander claimed that the district court erred in denying his motion to suppress evidence obtained by law enforcement after they entered his apartment without a warrant or his consent. The case revolved around the question of warrantless entry and consent.The court held that the warrantless entry into Alexander's apartment did not violate the Fourth Amendment. This was because the officers reasonably believed that Alexander's girlfriend, identified as E.B., had the apparent authority to consent to their entry. E.B. had called the police to report domestic violence, and when the officers arrived, she opened the door to the apartment and stepped inside, holding the door open for the officers. This action was seen as an invitation for the officers to enter the apartment.The court also found that E.B. had given implied consent for the officers to enter the apartment based on her nonverbal gestures and actions, such as opening the door and stepping inside when asked about the location of her boyfriend. Considering the totality of the circumstances, the court ruled that the officers' reliance on E.B.'s apparent authority to consent to their entry was reasonable. As such, the district court's decision to deny Alexander's motion to suppress the evidence was affirmed. View "Alexander v. The State of Wyoming" on Justia Law

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Travis James Wright, found guilty of two counts of sexual exploitation of children, appealed the denial of his motion for sentence reduction by the District Court of Carbon County. He had been sentenced to two concurrent sentences of eight to ten years. Wright filed a pro se motion for sentence reduction, arguing prosecutorial misconduct, the proportionality of his sentence, and providing personal information and letters of support. The Supreme Court of Wyoming affirmed the lower court's decision, noting that the district court did not abuse its discretion in denying the motion. The court explained that it reviews rulings on motions for sentence reduction for abuse of discretion, and the sentencing judge is in the best position to decide about sentence modification. The court found that Wright's claims were not supported by cogent argument and were not appropriate under a Rule 35(b) motion, which cannot be used to attack the validity of a conviction or as a substitute for a properly filed appeal. The court also noted that productive behavior alone does not require the district court to grant a sentence reduction. View "Wright v. The State of Wyoming" on Justia Law

Posted in: Criminal Law
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In a case before the Supreme Court of Wyoming, Kristina Croy, a daycare operator, was found guilty of involuntary manslaughter following a six-day jury trial. The charges stemmed from an incident in which an eight-month-old infant, MG, in her care died due to positional asphyxia resulting from being improperly swaddled. Croy appealed, arguing, among other things, that there was insufficient evidence to support the jury's verdict. The Court affirmed the conviction, stating there was sufficient evidence for the jury to conclude that swaddling MG posed a substantial and unjustifiable risk of death, and that Croy had consciously disregarded that risk. The Court also ruled that the trial court did not abuse its discretion when it dismissed a juror who had discussed the case with another juror prior to deliberations, violating the court's instructions not to prejudge the case. Furthermore, the Court determined that the trial court did not abuse its discretion or deprive Croy of a fair trial when it declined her request to impose restrictions on how the State split its time between closing summation and rebuttal argument. The Court's decision was based on the particular facts of the case, noting that Croy could not demonstrate that there was a reasonable probability the verdict might have been more favorable to her if the prosecutor had not been allowed to make a lengthy rebuttal argument. View "Croy v. The State of Wyoming" on Justia Law