Justia Wyoming Supreme Court Opinion Summaries

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

A man was convicted by a jury of sexually abusing his ten-year-old stepgranddaughter on two occasions in 2022. The abuse included inappropriate touching and digital penetration, occurring once in May and again in late August at the child’s home while he was babysitting. The child disclosed the abuse to her mother several weeks later, which led to a police investigation. During the investigation, the man denied the allegations and agreed to take a polygraph examination, which indicated no deception regarding whether he had touched the child’s vagina or buttocks on a specific Sunday in August. However, the abuse was alleged to have occurred on a Saturday and in May.The District Court of Campbell County presided over the trial. At trial, the State moved to exclude any reference to the polygraph examination, arguing it was inadmissible under Wyoming Rules of Evidence 702 and 403. The court granted the motion, and the jury found the defendant guilty on all counts. He was sentenced to consecutive prison terms. While his direct appeal was pending, the defendant filed a motion for a new trial under Wyoming Rule of Appellate Procedure 21, claiming ineffective assistance of counsel for failing to request a Daubert hearing on the admissibility of the polygraph results. After an evidentiary hearing, the district court denied the motion, finding no prejudice because the polygraph evidence would not have been admissible.The Supreme Court of Wyoming reviewed the consolidated appeals, focusing solely on the denial of the Rule 21 motion. The court held that the defendant failed to show prejudice, as the polygraph results would not have satisfied the requirements for admissibility under Daubert and Rule 702, nor would they have assisted the jury or fit the facts of the case. The court affirmed the district court’s denial of the motion for a new trial. View "Morris v. The State of Wyoming" on Justia Law

On November 25, 2023, a Casper Police Department officer conducted a welfare check on David Wayne Gober, who was found walking in the street. After determining Gober was not in distress, the officer ran his name and discovered an active warrant for failure to pay a fine. Upon arresting Gober, officers searched him and found glass pipes, jeweler’s bags containing a small amount of a crystal-like substance, metal tooter pipes, and unused syringes. The substances in the pipes and bags tested positive for methamphetamine. Gober was charged with felony possession of a controlled substance, methamphetamine, as it was a third or subsequent offense.The District Court of Natrona County presided over Gober’s jury trial. During the trial, Gober argued that the methamphetamine found was only a trace amount and proposed a de minimis infraction theory of defense instruction, which would allow the jury to acquit if the conduct was too trivial to warrant conviction. The district court refused to give this instruction, reasoning that Wyoming law does not set a minimum amount of methamphetamine for criminal liability and that the proposed instruction was not a recognized defense under Wyoming law. The jury found Gober guilty, and he was sentenced to two to four years’ imprisonment, suspended in favor of two years’ supervised probation.The Supreme Court of Wyoming reviewed the case. It held that the district court properly refused Gober’s proposed de minimis infraction instruction because Wyoming law criminalizes knowing or intentional possession of any amount of methamphetamine, regardless of quantity. The court found that the de minimis infraction defense is not recognized by Wyoming statute or case law for this offense and that the instruction would have improperly invited jury nullification. The Supreme Court of Wyoming affirmed the district court’s judgment. View "Gober v. State" on Justia Law

A law enforcement officer observed a black sedan at a busy intersection in Campbell County, Wyoming. The sedan, driven by Andrew Boyer, was in the right lane behind an SUV. When the light turned green, the SUV did not move, and Boyer overtook it on the right to turn east, remaining on the paved surface. The officer, concerned about the safety of this maneuver and suspecting a traffic violation, followed Boyer. While following, dispatch informed the officer that the vehicle’s registered owner, Boyer, did not have a valid driver’s license. After stopping Boyer, the officer confirmed his identity and learned he possessed a physical license, though the officer knew this did not guarantee valid driving privileges. During the stop, a K-9 unit alerted to drugs in the vehicle, leading to a search that uncovered methamphetamine, marijuana, and drug paraphernalia.Boyer was charged with several drug-related offenses and moved to suppress the evidence, arguing the stop was not supported by reasonable suspicion and that the scope of the stop was improperly expanded. The District Court of Campbell County denied the motion, finding the officer had reasonable suspicion both from observing the overtaking maneuver and from dispatch’s information about Boyer’s license status. The court also found the stop was not unnecessarily prolonged.On appeal, the Supreme Court of Wyoming reviewed whether the district court erred in denying the motion to suppress. The court held that the officer had reasonable suspicion to justify the initial stop based on both the observed traffic violation and the information from dispatch regarding Boyer’s license. The court concluded that the stop did not violate the Fourth Amendment, as the officer’s actions were reasonable under the totality of the circumstances. The Supreme Court of Wyoming affirmed the district court’s denial of the motion to suppress. View "Boyer v. The State of Wyoming" on Justia Law

Between 2017 and 2023, a woman applied for and received welfare benefits for herself and her three children under three government programs: SNAP, Medicaid, and LIEAP. During this period, she did not list the children’s father as a household member on any of her applications, despite evidence that they lived together. She also failed to disclose several assets, including joint bank accounts, a timeshare, and other real property. An investigation by the Wyoming Department of Family Services revealed these omissions, leading to criminal charges.The State of Wyoming charged her with nineteen counts of welfare fraud, alleging that she knowingly made false statements or omitted material facts on her benefit applications, with each count involving benefits exceeding $500. The case proceeded to a bench trial in the District Court of Carbon County, where the State presented documentary evidence and witness testimony showing the woman and the children’s father shared addresses, held themselves out as a married couple, and jointly owned assets. The district court found her guilty on eighteen counts, concluding she knowingly misrepresented her household composition and failed to disclose assets, which affected her eligibility for benefits. She was sentenced to a split sentence of jail time and probation, with restitution ordered.On appeal, the Supreme Court of Wyoming reviewed whether the evidence was sufficient to support the convictions. Applying the standard that requires viewing the evidence in the light most favorable to the State, the court held that there was ample evidence for the district court to reasonably conclude the woman knowingly omitted the children’s father as a household member and failed to disclose joint assets. The Supreme Court of Wyoming affirmed the convictions for eighteen counts of welfare fraud. View "Fitzwater v. State" on Justia Law

Tyler James Hill pled guilty to involuntary manslaughter after an incident where he shot Ashley Bartel during an argument involving his mother, Rhonda Bryan. The shooting occurred when Hill produced a small pistol during the altercation, and the gun discharged after Bryan pushed Hill's arm, resulting in Bartel's death. Hill was charged with second-degree murder but later agreed to plead guilty to the lesser charge of involuntary manslaughter. The district court sentenced him to 15 to 20 years imprisonment.The district court of Laramie County denied Hill's motion to continue his sentencing hearing, despite his attorney filing a sentencing memorandum on the day of the hearing. Hill's attorney argued that the delay was due to the short notice and the July 4 holiday. The district court proceeded with the hearing, allowing Hill's attorney to present the contents of the memorandum orally. The court ultimately sentenced Hill to 15 to 20 years imprisonment, finding him not suitable for probation.The Supreme Court of Wyoming reviewed the case and affirmed the district court's decisions. The court held that the district court did not abuse its discretion in denying Hill's motion to continue the sentencing hearing, as the defense counsel was able to present the mitigating evidence orally during the hearing. Additionally, the court found that Hill did not receive ineffective assistance of counsel, as he could not demonstrate that the outcome of his sentencing would have been different if the memorandum had been filed earlier. The court concluded that Hill was not prejudiced by his counsel's performance. View "Hill v. State" on Justia Law

Logan Gregory Gosselin pled guilty to one count of sexual exploitation of a child and was sentenced to three to eight years in prison, with a recommendation for the Youthful Offender Transition Program (YOTP). Nearing completion of the YOTP, Gosselin filed a motion for sentence reduction, which the district court denied. Gosselin appealed, arguing that the district court abused its discretion and violated his constitutional rights by not honoring an earlier promise to reduce his sentence upon successful completion of the YOTP.The district court of Laramie County initially sentenced Gosselin and included a written judgment suggesting an expectation of sentence reduction if he completed the YOTP. However, the judge who issued the original sentence retired, and a new judge denied Gosselin's motion for sentence reduction without a hearing. Gosselin's appeal contended that the denial was an abuse of discretion and violated his due process and double jeopardy rights.The Wyoming Supreme Court reviewed the case and found that the district court did not abuse its discretion. The court clarified that the written judgment's language about an "expectation" of sentence reduction did not constitute a binding promise. The court also determined that the district court's oral pronouncement did not guarantee a sentence reduction but merely indicated that Gosselin would likely return to court to request it. The Supreme Court held that the district court's denial of the motion did not violate Gosselin's due process rights, as there was no protected interest in a guaranteed sentence reduction. Additionally, the court found no double jeopardy violation, as the denial of the motion did not increase Gosselin's original sentence. The Wyoming Supreme Court affirmed the district court's decision. View "Gosselin v. State" on Justia Law

Michael Isreal Robin, Sr. was convicted by a jury on multiple counts, including theft of a vehicle, possession of cocaine, property destruction, possession of methamphetamine, and possession of marijuana. The appeal focuses solely on the conviction for theft of a vehicle. Robin contends that the State of Wyoming presented insufficient evidence to prove he exercised control over the vehicle without the owner's authorization.The District Court of Laramie County held a two-day jury trial in November 2024. The State called two witnesses: the investigating officer and the vehicle's owner, Gloria Landeroz. Officer Maljian testified about the surveillance and subsequent high-speed chase that led to Robin's arrest. Landeroz testified that she had loaned the vehicle to Robin but expected it to be returned before the day of the crash. She was uncertain about the exact dates but clarified that Robin did not have permission to use the vehicle on the day of the incident. Robin's motion for a judgment of acquittal was denied by the district court, and the jury found him guilty of vehicle theft.The Supreme Court of Wyoming reviewed the case, focusing on whether the State presented sufficient evidence to support the conviction. The court noted that the standard of review requires assuming the State's evidence is true and giving the State the benefit of every favorable inference. The court found that Landeroz's testimony, despite her memory issues, provided sufficient evidence for the jury to conclude that Robin did not have authorization to use the vehicle at the time of the incident. The court affirmed the conviction, holding that a reasonable jury could have found Robin guilty beyond a reasonable doubt based on the evidence presented. View "Robin v. State" on Justia Law