Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court reversed Defendant's conviction of aggravated assault and battery for shooting a man at a campground, holding that the district court erred when it refused to give Defendant's proposed "castle doctrine" instructions.Defendant was charged with aggravated assault and battery in violation of Wyo. Stat. 6-2-502. Defendant filed a motion to dismiss arguing that he had acted in self-defense and was immune from prosecution under the "castle doctrine." See Wyo. Stat. 6-2-602(f). The district court denied the motion to dismiss, and a jury convicted Defendant of aggravated assault and battery. On appeal, Defendant argued the district court erred when it refused to give his proposed castle doctrine instructions. The Supreme Court reversed, holding (1) Defendant presented competent evidence to create factual issues about whether his vehicle was adapted for overnight accommodation and fit within the definition of "habitation" and whether the victim was in the process of unlawfully and forcefully entering that habitation when he was shot; and (2) because the district court did not allow these factual questions be resolved by the jury, a new trial was required. View "Howitt v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for two counts of felony child endangerment and one count of misdemeanor possession of methamphetamine, holding that the prosecutor's comments during opening and closing statements were not prejudicial to Defendant.After a jury trial, Defendant was convicted of two counts of felony child endangerment and one count of misdemeanor possession of a controlled substance. The district court sentenced Defendant to three to five years in prison for the endangerment counts, to run concurrently with each other. The Supreme Court affirmed, holding that Defendant failed to establish that two almost identical statements made by the prosecutor before trial denied Defendant a substantial right or materially prejudiced his case. View "Lott v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of felony property destruction and defacement, holding that there was sufficient evidence to support the conviction and that the prosecutor did not commit misconduct during his rebuttal argument.After a jury trial, Defendant was found guilty of felony property destruction and defacement. Defendant appealed, arguing that there was insufficient evidence to support his conviction and that a statement made during the prosecutor's rebuttal closing argument amounted to misconduct. The Supreme Court affirmed, holding (1) sufficient evidence supported the conviction; and (2) the prosecutor did not engage in misconduct during rebuttal closing argument. View "Ogden v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony property destruction, sentencing him to a term of imprisonment and probation, and ordering restitution in favor of the victim, holding that there was no error in the restitution order.Defendant pled guilty to felony property destruction. The district court sentenced Defendant to three to five years in prison, suspended in favor of the three years of probation. The district court then ordered restitution in the amount of $7,398. Defendant appealed, challenging the sufficiency of the evidence supporting the restitution award. The Supreme Court affirmed, holding that Defendant waived his right to contest the factual basis for the court's restitution order when he failed timely to object to the victim's damages identified in the presentence investigation report. View "Corr v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Appellant's declaratory judgment action against Wyoming Governor Mark Gordon and the Wyoming Board of Parole, holding that the district court did not err in concluding that Appellant lacked standing to bring his claims.Appellant, an inmate serving a life sentence and a consecutive five-to-ten-year sentence for crimes to which he pled guilty in 1989, brought this action seeking a declaration that Wyoming's commutation procedures are unconstitutional. The district court dismissed the action, concluding that Appellant lacked standing and that Wyoming's commutation procedures did not violate Appellant's constitutional rights. The Supreme Court affirmed, holding (1) because Appellant did not have an existing or genuine interest in or right to commutation he lacked standing to bring his declaratory judgment action; and (2) commutation decisions involve a political question that is not an appropriate subject for judicial review. View "Weldon v. Honorable Mark Gordon" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree sexual abuse of a minor and sentence of two consecutive terms of five to seven years in prison, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued, among other things, that the district court abused its discretion at sentencing by excluding argument and testimony that the victim's parents condoned Defendant's sexual abuse of their daughter and financially extorted him after learning of the abuse. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion at sentencing by refusing to hear argument and testimony that the victim's parents condoned the abuse and used the abuse for financial gain; and (2) properly imposed consecutive sentences of imprisonment rather than probation. View "Villafana v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony shoplifting after a jury trial, holding that the district court did not err or abuse its discretion.On appeal, Defendant argued that his right to a speedy trial was violated and that the district court abused its discretion by allowing a juror who inadvertently saw a video about the trial on social media to remain on the jury. The Supreme Court disagreed and affirmed, holding (1) Defendant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48 or the Sixth Amendment; and (2) Defendant waived any claim related to alleged juror impropriety by not objecting before the return of the verdict. View "Vlahos v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of second-degree murder for the shooting death of his significant other, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the district court did not abuse its discretion when it admitted a certain text message as other acts evidence under Wyo. R. Evid. 404(b); (2) the district court did not abuse its discretion when it permitted the State’s forensic pathologist to opine as to the victim’s manner of death; and (3) there were no clearly improper leading questions involving the prosecutor's personal beliefs or reference to facts not in evidence. View "Anderson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of burglary and other offenses, holding that the district court did not err admitting WiFi records showing Defendant's Apple iPhone connected to his workplace's password-protected WiFI network on the night of the burglary giving rise to Defendant's convictions.Defendant was convicted of burglary, theft, and property destruction for breaking into his workplace and stealing approximately $16,000 in cash. On appeal, Defendant argued that the district court erred in ruling that there was sufficient foundation to allow the WiFi records at issue. The Supreme Court affirmed, holding that assuming that the WiFi records were hearsay, the district court did not abuse its discretion in admitting the evidence under the business records exception. View "Blair v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's pre-sentence motion to withdraw his plea of no contest to second-degree murder, holding that the district court did not abuse its discretion.Defendant pleaded no contest to second-degree murder and guilty to first-degree arson, felony theft, and felony burglary. Before sentencing, Defendant filed a pro se motion to withdraw his no-contest plea, alleging that he made the decision to enter the no-contest plea due to ineffective assistance of counsel. After a hearing, the district court denied the motion, ruling that Defendant failed to establish a basis to withdraw his no-contest plea. The Supreme Court affirmed, holding (1) Defendant failed to meet his burden of establishing there was a fair and just reason to allow him to withdraw his no-contest plea; and (2) the district court correctly exercised its discretion in denying Defendant's motion. View "Pettus v. State" on Justia Law