Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court reversed Defendant's conviction for third-degree sexual assault and false imprisonment, holding that the district court erred in denying Defendant's motion to transfer his case to juvenile court.Defendant was eighteen years old when the State charged him with offenses that he allegedly committed when he was seventeen years old. When Defendant moved to transfer his case to juvenile court, the State argued that the juvenile court lacked concurrent jurisdiction because Defendant was an adult when the charges were filed against him. The district court dismissed Defendant's transfer motion, concluding that the juvenile court's jurisdiction depended on Defendant's age when he was charged rather than his age when he committed the offense at issue. The Supreme Court reversed, holding that a juvenile court's concurrent jurisdiction under Wyo. Stat. Ann. 14-6-203(c) depends on an offender's age at the time of the offense, rather than at the time charges are filed. View "Rosen v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony murder, second-degree murder, aggravated burglary, and possession of a deadly weapon but remanded the cause for correction of an illegal sentence, holding that the sentence for first-degree felony murder was improper.After convicting Defendant, the district court sentenced Defendant to life in prison for felony murder and ten to fifteen years for aggravated burglary. The Supreme Court affirmed Defendant's conviction but remanded for correction of a sentencing error, holding (1) defense counsel's failure to secure a second psychological evaluation and failure to timely recognize that Defendant had not performed testing did not prejudice Defendant's defense; and (2) the imposition of multiple punishments for felony murder and the underlying felony violated the Double Jeopardy Clauses of the United States and Wyoming constitutions. View "Steplock v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of four felonies - one count of attempted second degree sexual abuse of a minor and three counts of third degree sexual abuse of a minor - holding that Defendant validly waived his right to a jury trial.After a bench trial without any mention in the record that Defendant had waived his right to a jury trial, the court found Defendant guilty of the charged crimes. On appeal, Defendant argued that the court failed to ensure that his jury trial waiver complied with Wyo. R. Crim. P. 23(a) and was knowing, intelligent, and voluntary. The Supreme Court affirmed, holding that Defendant's jury trial waiver was valid. View "Ballard v. State" on Justia Law

The Supreme Court reversed Defendant's conviction for aggravated assault and battery, holding that a new trial was required because the district court abused its discretion by admitting certain testimony that prejudiced Defendant.After a jury trial, Defendant was found guilty for threatening to use a drawn deadly weapon on his wife. On appeal, Defendant argued that the district court abused its discretion by admitting his wife's testimony about a prior incident between her and Defendant in Park City, Utah because the testimony constituted uncharged misconduct evidence that was improperly admitted. The Supreme Court agreed and reversed, holding that the district court abused its discretion in admitting the Park City testimony and that the testimony prejudiced Defendant. View "Kincaid v. State" on Justia Law

The Supreme Court affirmed the order of the district court denying Appellant's motion to correct an illegal sentence, holding that Appellant's claim of an illegal sentence based on the facts supporting his conviction was barred by res judicata.Appellant pled guilty to escape and was sentenced to a two-to-three-year sentence to run concurrent with sentences Appellant had received for other crimes. Appellant later sent a letter that the district court interpreted as a motion to correct illegal sentence under Wyo. R. Crim. P. 35(a). The district court denied the motion as barred by the doctrine of res judicata. The Supreme Court affirmed, holding that Appellant's claim was barred by res judicata because he could have raised the issue in an earlier proceeding. View "Majhanovich v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to transfer his case to juvenile court, holding that the district court did not abuse its discretion in denying the motion to transfer the case to juvenile court.Defendant, a minor, was arrested and charged with nine counts of attempted first-degree minor after taking guns and ammunition to his high school planning to shoot nine particular individuals and as many other people as he could. Defendant filed a motion to transfer his case to juvenile court, but the motion was denied. The Supreme Court affirmed, holding that the district court appropriately analyzed and weighed the applicable factors under Wyo. Stat. Ann. 14-6-237(b) and did not abuse its discretion in denying Defendant's motion to transfer. View "Warner v. State" on Justia Law

The Supreme Court affirmed the decision of the Office of Administrative Hearings (OAH) upholding the decision of the Wyoming Department of Transportation (WYDOT) suspending Defendant's driver's license and operating privileges pursuant to Wyo. Stat. Ann. 31-6-102(e), holding that the OAH reasonably concluded as it did.Defendant was arrested for driving under the influence of alcohol. Because a breathalyzer test indicated that Defendant had a blood alcohol concentration greater than .08% the WYDOT suspended Defendant's driver's license. The OAH upheld the suspension. The Supreme Court affirmed, holding that substantial evidence supported the OAH's finding that law enforcement did not interfere with Defendant's right to obtain an independent chemical test under Wyo. Stat. Ann. 31-6-102(a)(ii)(C) and 31-6-105(d). View "Flauding v. State ex rel. Wyoming Department of Transportation" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of aggravated assault and battery, holding that prosecutorial misconduct did not prejudice Defendant.At trial, Defendant requested that the jury be instructed on self-defense. On appeal, Defendant argued that the prosecutor committed misconduct at trial when she misstated the law of self-defense to the jury three different times. The Supreme Court affirmed, holding that the prosecutor in this case did not misstate the law and that Defendant failed to show how the prosecutor's comments, considered cumulatively, prejudiced him. View "Mendoza v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of eight counts of forgery, holding that the district court did not err or abuse its discretion.On appeal, Defendant argued that the evidence was insufficient to show an intent to defraud and that the district court erred in instructing the jury on the required intent to defraud. The Supreme Court affirmed, holding that the district court (1) did not err in denying Defendant's motion for judgment of acquittal; and (2) did not abuse its discretion when it instructed the jury on the required element of intent to defraud. View "Bezold v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree sexual abuse of a minor, holding that the district court did not violate Defendant's right to a speedy trial.The State originally charged Defendant with one count of first-degree sexual assault and one count of delivery of a controlled substance, but sixteen days before trial, the State amended its information to include one count of second-degree sexual abuse of a minor. After a jury trial, Defendant was found guilty of second-degree sexual abuse of a minor. The Supreme Court affirmed, holding (1) Defendant's argument that the amendment to the indictment was untimely was waived because he failed to raise it below; and (2) Defendant was not deprived of his right to a speedy trial. View "Rogers v. State" on Justia Law