Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the district court's denial of Defendant's pre-sentence motion to withdraw guilty plea, holding that there was no error in the proceedings below.In 2020, the State filed a third petition to revoke Defendant's probation. Following the revocation proceeding, Defendant filed a motion to withdraw the guilty plea he had entered in 2017 on the grounds that the testimony he gave to support his plea was insufficient to establish a factual basis. The district court denied the motion. Thereafter, the court entered an order revoking Defendant's probation and entered judgment convicting him of burglary. The Supreme Court affirmed, holding that the district court properly denied Defendant's motion to withdraw his guilty plea because a sufficient factual basis existed for the plea. View "Reid v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming Defendant's license suspension, holding that law enforcement officers did not deprive Defendant of his right to an independent chemical test of his blood alcohol content, and therefore, his statutory and due process rights were not violated.Defendant was arrested for driving while under the influence of alcohol. Defendant submitted to a chemical breath test, which indicated that his blood alcohol concentration exceeded the legal limit. Defendant was advised of his right to obtain an independent chemical test at his own expense, and Defendant chose to exercise it. Defendant, however, never obtained the test. The Wyoming Department of Transportation suspended Defendant's driver's license for ninety days. Both the Office of Administrative Hearings and district court upheld the suspension. The Supreme Court affirmed, holding (1) substantial evidence supported the finding that law enforcement officers did not interfere with Defendant's right to obtain an independent blood test; and (2) the relevant statutes and substantive due process did not require law enforcement officers to do more than allow Defendant to go to the nearest hospital or clinic to obtain a test. View "Johnson v. State ex rel., Wyoming Department of Transportation" on Justia Law

The Supreme Court affirmed the judgment of the district court granting the State's petition to revoke Defendant's probation, holding that the district court did not abuse its discretion.Defendant pled guilty to conspiracy to deliver methamphetamine. The district court sentenced Defendant to three to four years of imprisonment but suspended his sentence on the condition that he successfully complete three years of supervised probation. The State subsequently petitioned to revoke Defendant's probation, claiming that Defendant violated a condition in his judgment and sentence. After a hearing, the court revoked Defendant's probation and sentenced him to a term of imprisonment. The Supreme Court affirmed, holding that there was no error or abuse of discretion. View "Farthing v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree murder, holding that Defendant's trial counsel was not ineffective for failing adequately to advise Defendant regarding his right to testify and in failing to present a defense.On appeal, Defendant challenged the district court's denial of his motion for a new trial, arguing that his trial counsel was deficient for denying him the ability to make a knowing and voluntary waiver of the right to testify and for failing to develop and prepare a defense. The Supreme Court affirmed, holding (1) Defendant made a knowing and voluntary decision not to testify; and (2) Defendant's failure to testify was not prejudicial. View "Richmond v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder, holding that there was no prejudicial error in the proceedings below.After a four-day trial, a jury convicted Defendant of first-degree murder. The district court sentenced Defendant to life imprisonment. The Supreme Court affirmed, holding (1) the circuit court did not err when it determined that Defendant was competent and fit to proceed; (2) the district court did not err when it determined that Defendant's statements to law enforcement were voluntarily made; and (3) there was sufficient evidence of premeditation for a jury to convict Defendant of first-degree murder. View "Snyder v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court determining that ASM, a middle-aged woman, needed to be involuntarily hospitalized pursuant to Wyo. Stat. Ann. 25-10-110 because she was mentally ill, as defined under section 25-10-101(a), holding that the district court did not err.Specifically, the Supreme Court held (1) upon review of the entire evidence, including ASM's testimony, the district court did not err when it found ASM to be mentally ill; and (2) the district court did not deny ASM her constitutional right to free exercise of religion under the United States and Wyoming constitutions when it ordered her involuntarily hospitalization in what ASM characterized as a "Catholic ritual of mortification" because ASM failed to establish that she was engaged in such a practice when she injured herself. View "ASM v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of obtaining property by false pretenses and ordering her to pay restitution, holding that there was no error in the restitution order.Based on her failure to disclose that she and her children were living with the father of two of her three children, Defendant received overpayments of supplemental nutrition and child care assistance. Defendant pled guilty to obtaining property by false pretenses, received a deferred prosecution, and was ordered to pay restitution. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in awarding restitution that included overpayments for time period during which Defendant asserted she was eligible for assistance; and (2) Defendant waived the question of whether the district court erred when it ordered restitution that included benefits attributable to the father's income. View "Belanger v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions of one count of aiding and abetting attempted second-degree murder, one count of reckless endangering, and one count of misdemeanor possession of methamphetamine, holding that the district court did not err in denying Defendant's request for a jury instruction on the lesser-included offense of accessory to attempted voluntary manslaughter.Defendant was a passenger in her co-defendant's vehicle when the co-defendant led law enforcement on a high speed chase. Defendant was convicted for her part in the crimes committed. The Supreme Court affirmed Defendant's convictions but remanded for correction of the district court's written sentencing order, holding (1) the district court did not err when it declined to give Defendant's proposed jury instruction on the lesser-included offense of accessory to attempted voluntary manslaughter; and (2) the court's written sentencing order deviated from its oral pronouncement. View "Jacobs v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of one count of felony strangulation of a household member and one count of misdemeanor domestic battery, holding that there was no error.On appeal, Defendant argued that the district court violated his due process rights when it refused to allow him to plead guilty to domestic battery and by refusing to accept his guilty plea. The Supreme Court affirmed, holding (1) Defendant failed to establish that he had a protected due process interest in changing his plea to guilty; and (2) the district court did not abuse its discretion when it denied Defendant's request to change his pleas. View "Miller v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of third-degree sexual assault and sentencing him to a sentence of five to eight years in prison, holding that there was no error in the proceedings below.Defendant entered an Alford plea to third-degree sexual assault. On appeal, Defendant argued two arguments relating to his competency at sentencing. The Supreme Court affirmed, holding (1) the district court did not err in imposing Defendant's sentence without first making an oral finding that Defendant was competent to proceed; and (2) the district court did not err by making a written finding that Defendant was competent to proceed with sentencing rather than sua sponte suspending the sentencing hearing and ordering him to undergo a third competency evaluation. View "Merlak v. State" on Justia Law