Justia Wyoming Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed Defendant's conviction of second-degree murder and aggravated assault, holding that the district court did not err in denying Defendant's motion to suppress statements he made at the scene of the crime and during a recorded interview.On appeal, Defendant argued that the admission of the challenged statements violated his rights under the Fifth and Fourteenth Amendment because he was not informed of his Miranda rights before he was questioned and because he was under the influence of methamphetamine at the time of the recorded interview. The Supreme Court affirmed, holding that the district court (1) did not err when it found Defendant's statements at the scene fell under the public safety exception to Miranda; and (2) did not err when it found that Defendant voluntarily waived his Miranda rights at the police station. View "Schwartz v. State" on Justia Law

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The Supreme Court remanded this criminal case to the district court sentencing Defendant for methamphetamine possession, holding that this Court could not reach the issue on appeal of whether the district court erred when it used Defendant's prior Missouri conviction as a basis for an enhanced sentence under Wyo. Stat. Ann. 35-7-1031(c)(i).Defendant entered into a conditional guilty plea agreement reserving the right to appeal his conviction based on his argument that his prior Missouri convictions did not subject him to enhanced penalties b because they were not violations of a "similar law" under the Wyoming statute. The Supreme Court remanded the case for further proceedings, holding that the Court could not determine from the record which statutes or ordinances underlay Defendant's prior convictions. View "Stanger v. State" on Justia Law

Posted in: Criminal Law
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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

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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

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The Supreme Court affirmed Defendant's conviction of first-degree sexual assault, holding that there was no error in the proceedings below but that remand was required for correction of a clerical error contained in the judgment and sentence.Specifically, the Supreme Court held (1) the district court did not err in denying Defendant's motion for a new trial because Defendant failed to show that trial counsel was constitutionally ineffective; (2) there was sufficient evidence to support a conviction of sexual assault in the first degree; and (3) the district court did not abuse its discretion in using a special verdict form that required the jury to answer questions related to the charged offense before it was required to make a finding of guilt. View "Neidlinger v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the district court concluding that Defendant was eligible to petition for relief from the duty to register as a sex offender only if he had been registered for twenty-five years, holding that the district court did not err.Thirteen years after his conviction of four-degree sexual assault, now codified as third-degree sexual assault, Defendant began registering as a sex offender when he learned he was obligated to do so by a change in the statute. Twenty-five years after his conviction, Defendant filed a petition seeking to be relieved of the duty to register. The district court granted the petition. When the Division of Criminal Investigation moved for relief from the judgment the district court. The district court granted the motion, holding that Defendant was eligible for relief only after he had been registered for twenty-five years. The Supreme Court affirmed, holding (1) the district court did not err when it interpreted the Wyoming Sex Offender Registration Act (WSORA); (2) the WSORA is not an ex post facto punishment; and (3) Defendant failed to raise a timely or cogent claim that the WSORA violated his constitutional right to protection. View "Harrison v. State" on Justia Law

Posted in: Criminal Law
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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

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The Supreme Court affirmed Defendant's conviction for aggravated animal cruelty and reckless endangering, holding that there was no error and that the evidence was sufficient to support the convictions.Defendant's convictions arose from a dog fight that resulted in a local teenager grabbing Rocky, a boxer, into the street and Defendant, the owner of the other dogs involved in the fight, shooting Rocky as he was held by the teenager. On appeal, Defendant argued that the district court erred in instructing the jury on the law of animal cruelty and that the evidence was insufficient to convict him of reckless endangering. The Supreme Court affirmed, holding (1) Defendant waived his argument that the jury instruction was confusing or misleading; (2) the district court properly denied Defendant's proposed elements instruction; and (3) the evidence was sufficient to sustain the conviction of reckless endangering. View "Mackley v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed Defendant's conviction of being an accessory to both involuntary manslaughter and aggravated assault and battery, holding that the district court erred when it refused to instruct the jury on defense of another.On appeal, Defendant argued that the evidence created a disputed issue of fact as to whether she was an aggressor in the dispute or was acting in defense of the victim throughout the conflict. The Supreme Court agreed, holding (1) defense of another is a recognized defense in this jurisdiction, Defendant's proffered instruction correctly stated the law, and the defense was supported by competent evidence; and (2) therefore, the district court erred when it refused to instruct the jury on defense of another. View "Smith v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's conviction of felony attempted interference with a peace officer and misdemeanor child endangerment, holding that the evidence was sufficient to support the convictions.On appeal, Defendant argued that the officer was not engaged in the lawful performance of his official duties when he used subdued Defendant and that the evidence was insufficient to support the finding that he had the specific intent to disarm the officer. The Supreme Court disagreed, holding (1) the evidence was sufficient to support the jury's finding that the officer did not use excessive force and was therefore engaged in the lawful performance of his duties when he subdued Defendant; and (2) there was sufficient evidence to show Defendant acted with the requisite specific intent. View "Latham v. State" on Justia Law

Posted in: Criminal Law