Justia Wyoming Supreme Court Opinion Summaries

James D. Van Winter moved in with his sister in Wyoming due to financial difficulties. After a family gathering, a dispute arose when Van Winter felt slighted by a guest, leading to a heated argument with his sister. The situation escalated when Van Winter refused to leave, resulting in a physical altercation with his brother-in-law. During the struggle, Van Winter threatened his brother-in-law with a pocketknife, which was later wrestled away, causing a minor injury. Police responded, collected statements and evidence, and Van Winter was arrested. He denied any altercation occurred.The State charged Van Winter with aggravated assault and battery and possession of a deadly weapon with unlawful intent. The District Court of Big Horn County presided over the jury trial, which resulted in convictions on both counts. At sentencing, the court orally imposed an 18–24 month prison term for Count I and a suspended 2–4 year sentence with probation for Count II. However, the written judgment imposed a suspended 3–5 year sentence and specified a three-year probation term. Van Winter appealed, arguing ineffective assistance of counsel for failing to present fingerprint evidence and challenging the discrepancy between the oral and written sentences.The Supreme Court of Wyoming reviewed the case. It held that Van Winter failed to demonstrate prejudice from his counsel’s performance, as the fingerprint evidence would not have changed the trial’s outcome given the consistent witness testimony. Therefore, the district court’s denial of the motion for a new trial was affirmed. However, the Supreme Court found a material conflict between the oral and written sentences for Count II. It vacated the probationary term and remanded the case for the district court to conform the written judgment to the oral pronouncement and to determine the appropriate length of probation. View "Van Winter v. The State of Wyoming" on Justia Law

Joel Lee Wilson was charged with aggravated burglary, robbery, breach of peace, property destruction, and unlawful possession of a controlled substance after forcibly entering the Wolf family’s home in Casper, Wyoming. The home was occupied by Alexander Wolf, a sheriff’s deputy, his wife, and their daughter. Wilson and another man, Daniel Hemmer, knocked and scratched at the door before Wilson broke it open. Upon entry, Wilson confronted the residents and engaged in a violent altercation with Mr. Wolf, while Hemmer interacted with the daughter. The incident ended with both men fleeing after Ms. Wolf intervened with a firearm. Evidence included Facebook messages between Wilson and Hemmer discussing an opportunity to make money and plans for the night, as well as Wilson’s statements to police about collecting a debt.The case was tried before the District Court of Natrona County. At trial, Wilson argued he lacked intent to commit theft, a required element for aggravated burglary and robbery, emphasizing that no property was taken and challenging the admission of the Facebook messages as co-conspirator statements. The district court denied Wilson’s motion for judgment of acquittal, finding sufficient evidence of intent based on the messages, the forceful entry, and the circumstances of the break-in. The jury convicted Wilson on all counts, and he was sentenced to concurrent prison terms.The Supreme Court of Wyoming reviewed whether sufficient evidence supported the jury’s finding of intent to commit theft. Applying the standard of review that favors the State’s evidence and reasonable inferences, the court held that both direct and circumstantial evidence—including the Facebook messages, Wilson’s conduct, and the coordinated entry—supported the jury’s verdict. The court affirmed the convictions, concluding the evidence was sufficient to establish Wilson’s intent to commit theft. View "Wilson v. The State of Wyoming" on Justia Law

In this case, law enforcement officers responded to a domestic disturbance at a residence where they found the defendant holding his pregnant fiancée by the wrists. The officers directed him to remain seated on the kitchen floor during their investigation, which lasted about forty minutes. During this time, the defendant was told he was not under arrest but was not free to leave. He eventually admitted to restraining his fiancée by the chin and neck and taking her to the ground. He was later arrested and charged with several offenses, including aggravated assault and battery.After a preliminary hearing in the Circuit Court, the case was bound over to the District Court of Albany County. The defendant moved to suppress statements made before his formal arrest, arguing they were obtained during a custodial interrogation without Miranda warnings. The State opposed, contending he was not in custody until his formal arrest. The District Court held a hearing, denied the motion to suppress, and accepted the defendant’s conditional guilty plea to aggravated assault, reserving his right to appeal the suppression ruling.On appeal, the Supreme Court of Wyoming reviewed whether the conditional guilty plea was valid under Rule 11(a)(2) of the Wyoming Rules of Criminal Procedure. The Court found that, although the plea was in writing, and both the State and the District Court approved it, the issue reserved for appeal—suppression of the defendant’s statements—was not dispositive. Independent evidence existed that could support conviction even if the statements were suppressed. Because the reserved issue was not dispositive, the conditional plea was invalid.The Supreme Court of Wyoming vacated the judgment of conviction and reversed and remanded the case to the District Court for further proceedings. The main holding is that a conditional guilty plea is invalid if the issue reserved for appeal is not dispositive of the entire case. View "Kotrc v. The State of Wyoming" on Justia Law

A five-year-old child died after being left in the care of the defendant, who was the only adult present at the time. The defendant called 911, reporting the child had fallen down the stairs and was unresponsive. Emergency responders observed significant bruising and signs of oxygen deprivation. The child was transported to a hospital and died the next day. Law enforcement, suspecting abuse, interviewed the defendant at the police station. The defendant was advised of her Miranda rights, acknowledged understanding them, and agreed to speak with officers. Over several hours, during which she was allowed breaks and was not under arrest, the defendant ultimately confessed to beating the child and admitted fabricating the story about a fall.The State charged the defendant with first-degree murder and child abuse. The defendant moved to suppress her confession, arguing it was involuntary due to custodial circumstances, her use of prescription medication, and an invalid Miranda waiver. The District Court of Lincoln County held a suppression hearing without the defendant present, as she was hospitalized, and her counsel consented to proceeding in her absence. The court found the confession voluntary, denied the suppression motion, and admitted the confession at trial. The jury convicted the defendant on both charges.On appeal, the Supreme Court of the State of Wyoming reviewed whether the district court erred in finding the confession voluntary and in conducting the suppression hearing without the defendant present. The Supreme Court held that, under the totality of the circumstances, the confession was voluntary and not the result of coercion or impairment. The court also found that any error in holding the suppression hearing without the defendant was harmless, as there was no reasonable probability her presence would have changed the outcome. The convictions and rulings of the district court were affirmed. View "Marler v. The State of Wyoming" on Justia Law

A nineteen-year-old man was convicted for his involvement in two murders in Wyoming. He was sentenced in 2006 to three consecutive terms of life imprisonment without the possibility of parole, following a jury trial in which he was acquitted of one count of first-degree murder but convicted of conspiracy to commit murder and first-degree murder for the other offenses. The crimes involved the killing of a roommate and a sixteen-year-old, with the defendant playing a significant role in both. At sentencing, the jury declined to impose the death penalty and instead issued mandatory life without parole sentences, as required by Wyoming law at the time.After his direct appeal was denied by the Wyoming Supreme Court, the defendant filed a motion in 2024 to correct his sentences, arguing that mandatory life without parole for “emerging adults” (those aged eighteen to twenty-one) is unconstitutional under both the Wyoming and United States Constitutions. He claimed that new scientific evidence and evolving legal standards, particularly those established in Miller v. Alabama and related U.S. Supreme Court cases, should extend protections against mandatory life without parole to offenders in his age group. The District Court of Campbell County denied his motion, finding that the relevant constitutional protections and precedents did not apply to adults over eighteen.The Supreme Court of Wyoming reviewed the case and affirmed the district court’s decision. The court held that the Wyoming Constitution does not provide broader categorical protections for “emerging adults” than the Eighth Amendment. It concluded that the state’s constitutional provisions on cruel or unusual punishment and on the penal code’s humane principles do not prohibit mandatory life without parole sentences for offenders over eighteen. The court also found no violation of equal protection or entitlement to a new sentencing hearing. The holding clarified that, while Wyoming’s constitution is distinct from the federal constitution, it does not require categorical relief for emerging adults sentenced to life without parole. View "Hicks v. The State of Wyoming" on Justia Law

The case concerns a man who, after being separated from his wife of six months, engaged in repeated and escalating contact with her, including hostile voicemails, text messages, and physically aggressive behavior such as banging on her door and damaging property. After being served with divorce papers, his conduct intensified, including following her, driving by her residence and her mother’s house, and sending threatening messages. One particular text message stated he had “nothing to lose,” would “go back to prison,” and would “die before I go back.” Law enforcement was contacted, and during a recorded conversation with an officer, he again referenced the possibility of returning to prison.The District Court of Sheridan County charged him with felony stalking, based on his conduct and a prior stalking conviction. The prosecution sought to introduce evidence under Wyoming Rule of Evidence 404(b), including the text and recorded statement referencing prison, to show intent, motive, and consciousness of guilt. The district court held a hearing, conducted the required analysis under Gleason v. State, and admitted the text and recorded statement for the stated purposes, while excluding other references to his prior conviction. At trial, the jury found him guilty, and he was sentenced to four to eight years in prison.On appeal, the Supreme Court of Wyoming reviewed whether the district court abused its discretion in admitting the text and recorded statement under W.R.E. 404(b). The court held that the district court properly admitted the evidence, as it was relevant to show intent, motive, and consciousness of guilt, and its probative value was not substantially outweighed by unfair prejudice. The Supreme Court of Wyoming affirmed the conviction. View "Bragdon v. The State of Wyoming" on Justia Law

A defendant was charged with two counts of second-degree sexual abuse of a minor and one count of third-degree sexual abuse of a minor, based on allegations that he engaged in sexual acts with a 15-year-old girl. The alleged conduct included both acts of sexual intrusion and other sexually related behavior. The defendant denied any sexual contact, while the victim and another witness provided testimony about the events. Forensic evidence was inconclusive, and the defendant’s police interview was played for the jury. The jury acquitted the defendant on the two counts of second-degree sexual abuse but convicted him on the third-degree charge.The District Court of Natrona County conducted the trial and provided jury instructions that did not specifically exclude conduct that would qualify as first- or second-degree sexual abuse from the third-degree charge, nor did they specify the factual basis for the third-degree charge. Defense counsel agreed to the instructions as given and specifically requested that the instructions not exclude the conduct alleged in the other counts. After the jury returned its verdict, the defendant appealed, arguing that the jury instructions were erroneous for not excluding first- or second-degree conduct from the third-degree charge and for failing to specify the conduct underlying the third-degree charge.The Supreme Court of Wyoming reviewed the case. It held that the defendant had affirmatively waived any objection to the lack of an instruction excluding first- or second-degree conduct from the third-degree charge by requesting that such language be omitted, invoking the invited error doctrine. The court further held that the district court did not plainly err by failing to specify the factual basis for the third-degree charge in the jury instructions, as there was no clear and unequivocal rule of law requiring such specificity when only a single count was at issue. The Supreme Court of Wyoming affirmed the conviction. View "Townsend v. The State of Wyoming" on Justia Law

Law enforcement officers stopped an individual for a traffic violation and, during the stop, discovered a small amount of cocaine and marijuana in his vehicle, along with over $23,000 in cash hidden in various locations. After his arrest, the individual admitted to law enforcement that he had purchased and distributed controlled substances and that about half of the seized money was from drug sales, with the remainder allegedly from a 401k and insurance settlement. A subsequent search of another vehicle he owned, prompted by his statements, led to the discovery of additional drugs and over $31,000 in cash. In total, $54,226 was seized. The individual was charged with and pled guilty to two counts of misdemeanor possession of a controlled substance.The State of Wyoming initiated a civil forfeiture action in the District Court of Carbon County, seeking to forfeit the seized currency under the Wyoming Controlled Substances Act. The State alleged the money was either proceeds from drug sales or intended to facilitate further violations of the Act. After a bench trial, the district court ordered the forfeiture of the currency, applying a preponderance of the evidence standard to determine that the money was subject to forfeiture. The individual appealed, arguing that the district court applied the wrong burden of proof and improperly considered offenses beyond those for which he was convicted.The Supreme Court of Wyoming held that the district court erred by applying the preponderance of the evidence standard rather than the statutorily required clear and convincing evidence standard to determine whether the currency was subject to forfeiture. The court reversed the forfeiture order and remanded for further proceedings under the correct standard. The court also clarified that, in forfeiture proceedings, the district court may consider violations of the Wyoming Controlled Substances Act beyond the specific offenses for which the individual was arrested or convicted. View "In the Matter of U.S. Currency Totaling $54,226.00" on Justia Law

The case involved a defendant who was charged with one count of first-degree sexual abuse of a minor and four counts of second-degree sexual abuse of a minor, based on allegations made by his stepdaughter (IB) and his biological daughter (TL). The allegations surfaced during a Department of Family Services investigation into the household, which led to forensic interviews of the children. Both IB and TL described incidents of sexual abuse involving the defendant. The defendant challenged the competency of the two minor victims to testify and, during trial, objected to the late disclosure of a follow-up interview with another child, JL, which contained statements about attempted abuse.The District Court of Campbell County held a pretrial hearing to determine the competency of IB and TL, ultimately finding both children competent to testify. During trial, after a forensic interviewer referenced JL’s follow-up interview, the defense moved for a mistrial, arguing a discovery violation. The district court denied the motion, instead striking the testimony and instructing the jury to disregard it, while also providing the defense with the interview recording and the opportunity to recall witnesses. The jury convicted the defendant on all counts, and the district court imposed consecutive and concurrent sentences totaling several decades in prison.On appeal, the Supreme Court of the State of Wyoming reviewed whether the district court abused its discretion in finding the children competent to testify and in denying the motions for mistrial. The Supreme Court held that the district court did not abuse its discretion in either respect. The court found the children’s testimony established their competency and that the late disclosure of JL’s interview did not constitute a Brady or Giglio violation, as the evidence was made available during trial and was not material to the defense. The Supreme Court affirmed the convictions and the district court’s rulings. View "Lake v. State of Wyoming" on Justia Law

The case concerns a man who was convicted of first-degree arson after a fire occurred in his trailer home in Gillette, Wyoming. On the morning of the incident, a neighbor saw him borrow a lighter and leave the area; shortly after, smoke was observed coming from his trailer. The man was later seen at a nearby business, covered in bleach, and subsequently changed clothes before arriving at his ex-girlfriend’s house, where he smelled of cleaning supplies. Firefighters found multiple intentionally set fires inside the locked trailer, with no evidence of forced entry or accidental cause. The trailer was uninsured, and the defendant denied starting the fire, testifying that he was searching for his dogs at the time.The District Court of Campbell County held a jury trial, during which the defendant was found guilty of first-degree arson and sentenced to eight to fourteen years in prison. The defendant appealed, arguing that the evidence was insufficient to support his conviction and that the court erred by excluding evidence suggesting an alternative suspect—a former tenant who had previously threatened to burn down the trailer.The Supreme Court of Wyoming reviewed the case. It held that there was substantial circumstantial evidence from which a jury could reasonably infer the defendant’s guilt beyond a reasonable doubt, including his presence at the scene, the locked state of the trailer, the use of bleach, and the lack of evidence of another perpetrator. The court also held that the district court did not abuse its discretion in excluding the alternative suspect evidence, finding it to be inadmissible hearsay and lacking a direct nexus to the crime. The Supreme Court of Wyoming affirmed the conviction. View "Boyer v. The State of Wyoming" on Justia Law