Justia Wyoming Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed the judgment of the district court convicting Defendant of possession of methamphetamine, holding that the district court's statements to the jury did not constitute reversible error and that the evidence was sufficient to support the conviction. During trial, the district court advised the jury that they might want to wear gloves before examining the evidence of a baggie containing the methamphetamine. On appeal, Defendant argued that the district court's remarks about the evidence were error per se or, in the alternative, plain error and that the evidence was insufficient to establish the "knowledge" element of the crime. The Supreme Court affirmed, holding (1) the district court did not inject bias into the proceedings or interfere with the jury's fact-finding role, and even if the statements in question were in error, Defendant failed to demonstrate material prejudice to a substantial right; and (2) there was sufficient evidence to support a guilty verdict beyond a reasonable doubt. View "Sorensen v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the district court convicting Defendant of aggravated assault and battery, driving under the influence of a controlled substance, and unlawful use of a toxic substance, holding that the district court did not err in convicting Defendant for aggravated assault and battery. Specifically, the Court held (1) the "knowingly" requirement of Wyo. Stat. Ann. 6-2-501(a)(ii) did not require the State to prove that Defendant purposefully hit the victim's vehicle, but rather, Defendant's knowing and voluntary act of continuing to drive while under the influence of an inhalant provided the required mens rea to impose criminal liability for aggravated assault and battery under the statute; (2) the evidence was sufficient to support Defendant's conviction; and (3) the district court properly instructed the jury as to the statutory elements. View "Hopkins v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the trial court convicting Defendant of aggravated kidnapping, sexual abuse of a minor in the first degree, and sexual abuse of a minor in the second degree and sentencing Defendant to a term of eighty to 115 years in prison, holding that Defendant's claims of error were unavailing. Specifically, the court held (1) the district court did not err in denying Defendant's motion for a new trial because Defendant failed to show that his trial counsel was constitutionally ineffective; (2) the district court did not abuse its discretion in admitting other acts evidence under Wyo. R. Evid. 404(b); (3) there was sufficient evidence to sustain Defendant's aggravated kidnapping conviction; and (4) double jeopardy principles did not require the aggravated kidnapping and first-degree sexual abuse of a minor sentences to be merged. View "Winters v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting and sentencing Defendant for misdemeanor theft and felony property destruction, holding that Defendant was not entitled to relief on any of his assignments of error. Specifically, the Court held (1) the prosecutor did not commit misconduct by not controlling three of the state's witnesses, who provided non-responsive answers to certain questions, holding that there was no misconduct; (2) Defendant was not entitled to a judgment of acquittal on the charge of theft or on the charge of property destruction; and (3) the district court did not abuse its discretion in awarding $2,500 in restitution after the jury convicted Defendant of misdemeanor theft. View "Kuebel v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the district court dismissing a petition filed under the Post-Conviction Determination of Factual Innocence Act for failing to identify newly discovered evidence and for making conclusory claims, holding that the district court properly dismissed Appellant's petition on its initial review. The district court summarily denied Appellant's actual innocence petition for failing to cite newly discovered evidence that would clearly establish his factual innocence and for making irrelevant and conclusory allegations. The Supreme Court affirmed, holding (1) the district court did not err in finding that Appellant did not present newly discovered evidence his post-conviction petition for determination of factual innocence; and (2) the district court's denial was not premature in light of the district court's refusal to grant Appellant an evidentiary hearing. View "Sullivan v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the district court dismissing Appellant's complaint against the Wyoming Department of Corrections (WDOC) asking that the WDOC recognize Humanism as a religion, holding that the district court correctly dismissed Appellant's complaint as moot. Appellant, an inmate in the custody of the WDOC, brought this complaint under 42 U.S.C. 1983 seeking declaratory and injunctive relief and seeking money damages against the WDOC's director and its deputy administrator in their individual capacities. After Appellant filed his complaint, the WDOC officially recognized Humanism as a religion. Thereafter, the district court dismissed Appellant's complaint and denied Appellant's motion for attorney fees. The Supreme Court affirmed, holding (1) the voluntary cessation exception to the mootness doctrine has not been adopted in Wyoming; (2) Defendants were entitled to qualified immunity; and (3) Appellant was not a "prevailing party" under 42 U.S.C. 1988. View "Guy v. Lampert" on Justia Law

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The Supreme Court affirmed Defendant's convictions of one count each of felony stalking and burglary, holding that Defendant was not entitled to relief on any of his allegations of error. Specifically, the Court held (1) Defendant was not prejudiced when his counsel failed to file a motion to suppress statements Defendant made without receiving a Miranda warning; (2) review of Defendant's claim that the district court erred in failing to suppress Defendant's statements made without a Miranda warning was precluded; (3) the district court did not abuse its discretion in admitting body camera footage of Defendant's traffic stop; and (4) Defendant's convictions were supported by sufficient evidence. View "Bittleston v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court dismissing Appellant's petition seeking exoneration under the newly enacted Post-Conviction Determination of Factual Innocence Act, Wyo. Stat. Ann. 7-12-401 through 407, holding that the district court did not err when it dismissed the petition because it lacked documentation of any newly discovered evidence that would establish Appellant's innocence. Appellant, who was convicted for first degree murder and assault and battery, filed his petition for exoneration thirty-eight years after his convictions. The district court dismissed the petition without prejudice because it lacked any documentation of newly discovered evidence that would establish Appellant's innocence. The Supreme Court affirmed, holding that Appellant failed to comply with the statutory requirements of the Act, and therefore, the district court did not err when it dismissed the petition. View "Parkhurst v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the district court dismissing Appellant's pro se complaint filed under the Declaratory Judgment Act alleging that the Wyoming Department of Corrections (WDOC) violated certain policies and procedures during disciplinary proceedings brought against him, holding that Appellant was not entitled to relief. Specifically, the Court held (1) Appellant did not have standing to seek a general declaration that the WDOC must abide by its own rules and regulations, and the district court properly considered standing in dismissing Appellant's complaint even though the WDOC did not raise the standing issue in its motion to dismiss; and (2) collateral estoppel and res judicata barred Appellant's claims that procedural violations occurred during his disciplinary proceedings. View "Bird v. Lampert" on Justia Law

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The Supreme Court reversed Defendant's conviction for one count of incest, holding that the district court abused its discretion by permitting the State to use an expert to vouch for the credibility of the alleged victim, AS. On appeal, Defendant argued that the district court erred by allowing AS's counselor to testify that the "underlying basis" of AS's PTSD was her "reported sexual abuse." The Supreme Court affirmed, holding (1) the challenged testimony did more than "incidentally bolster" the credibility of AS; and (2) absent that testimony, there was a reasonable probability that Defendant would have enjoyed a more favorable verdict. View "Spence v. State" on Justia Law

Posted in: Criminal Law