Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of aggravated sexual assault and aggravated assault, holding that Defendant was not prejudiced by any alleged error in the jury instruction for rape and that the State had no duty under Brady v. Maryland, 373 U.S. 83 (1963), to conduct a forensic examination of the complainant's cell phone before trial.The court of appeals affirmed Defendant's convictions, holding that (1) the district court had not erroneously instructed the jury on the elements of rape, and (2) the State did not commit a Brady violation. The Supreme Court affirmed, holding (1) Defendant was not prejudiced by his counsel's failure to object to the jury instruction on the elements of rape, and, going forward, this Court endorses the use of Model Utah Jury Instruction 1605 for rape; and (2) the State did not violate Brady when it did not complete a forensic examination of the complainant's cell phone. View "State v. Newton" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of possession with intent to deliver a controlled substance, holding that the district court did not err in denying Defendant's motion to suppress.Defendant parked his car in a parking lot and was on his way into a bar when Officer Andy Lucus approached him and asked if they could talk. Defendant agreed. While they were talking, two other officers arrived at the scene. Officer Lucus asked if Defendant had proof of insurance. When Defendant could not locate his proof of insurance Officer Lucus wrote a "no insurance" citation. In the meantime, the other officers retrieved a K-9 named Lord to perform a free-air sniff of Defendant's vehicle. After Lord alerted to the smell of drugs Officer Lucus searched the vehicle and found methaphetamine. On appeal, Defendant conceded that his encounter with Officer Lucus began as consensual but asserted that the encounter changed to an unlawful investigatory detention when Officer Lucus requested proof of insurance. The Supreme Court affirmed without deciding the issue, holding that Lord's free-air sniff was lawful whether Defendant was free to leave or not. View "Kern v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for child abuse and lawful entry into an occupied structure, holding that Defendant waived his claim that the charge of unlawful entry did not state a criminal offense by pleading no contest to the charge.Defendant pleaded no contest to child abuse and unlawful entry after he entered the home where his estranged wife and teenage son were residing and hit the son with a wooden shovel handle. On appeal, Defendant argued that his unlawful entry must be overturned because it did not state a criminal offense. The Supreme Court affirmed, holding that Defendant waived his challenge to the unlawful entry count when he pleaded no contest to the charge. View "Dahl v. State" on Justia Law

The Supreme Court affirmed the 1992 sentence imposed on Defendant for crimes Defendant committed when he was fifteen years old, holding that Defendant's sentence was not a de facto life sentence entitling him to an individualized sentencing hearing under Miller v. Alabama, 567 U.S. 460 (2012).In 1992, Defendant was sentenced to three life sentences and one twenty-year to life sentence, all running concurrently, and one eighteen- to twenty-year sentence running consecutively to the other sentences. Here, Defendant filed a motion to correct an illegal sentence, claiming it was illegal in violation of Miller, Bear Cloud v. State, 334 P.3d 132 (Wyo. 2014), and their progeny. The district court denied the motion. The Supreme Court affirmed, holding that Defendant's 1992 sentence was not the functional equivalent of life in prison and that Defendant was not entitled to an individualized sentencing hearing under Miller. View "Wiley v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Defendant's motion to dismiss the State's case against him, holding that the district court applied the incorrect burden and standard when adjudicating Defendant's motion to dismiss, but the error was harmless.Defendant was charged with one count of first degree murder. The district court dismissed the case under Wyo. Stat. Ann. 6-2-602(f), which the legislature had recently added to the self-defense statutes. The Supreme Court granted the State's petition for writ of review to address matters of first impression regarding the statute's meaning and application. The Supreme Court held (1) section 6-2-602(f) is a mandatory immunity provision carrying with it a judicial gatekeeping function after the preliminary hearing; (2) the accused must present a prima facie showing that section 6-2-602(f) applies, and if the accused satisfies this minimal burden, the burden shifts to the State to establish by a preponderance of the evidence that section 6-2-602(f) does not apply; and (3) while the district court applied a different burden and standard when it adjudicated Defendant's motion to dismiss, its error was harmless. View "State v. John" on Justia Law

The Supreme Court affirmed the judgment of the district court imposing the maximum sentence of four and one-half to five years in connection with Defendant's plea of guilty to failure to register as a sex offender, holding that Defendant's failure to comply with the bond conditions contained in the plea agreement released the State from its obligation to recommend a reduced sentence.Defendant entered into a plea agreement with the State where, in exchange for his guilty plea, the State agreed to recommend a two-to three-year sentence, suspended in favor of two years of probation. The agreement incorporated Defendant's bond conditions requiring that he not be arrested or cited for a violation of the law. Before he was sentenced, Defendant received two citations for criminal trespass and one for false reporting. At sentencing, the State recommended that Defendant be sentenced to four to five years in prison. After he was sentenced, Defendant appealed, arguing that the State breached the plea agreement. The Supreme Court affirmed, holding that Defendant's breach of the plea agreement released the State from its obligation to recommend a reduced sentence. View "Springstead v. State" on Justia Law

The Supreme Court summarily affirmed the order of the district court denying Defendant's motion to enforce his claimed plea agreement, which the court treated as a Wyo. R. Crim. P. 35(a) motion, holding that Defendant's brief on appeal failed to comply with the Wyoming Rules of Appellate Procedure and contained no cogent argument or citation to pertinent authority.In exchange for Defendant's guilty plea, the State agreed that it would not seek the death penalty. The district court sentenced Defendant to life imprisonment. In his motion to enforce his claimed plea agreement, Defendant did no more than state his belief that he should have been required to serve no more than seven to eight years in prison for the first degree murder and reference a previously submitted commutation request. The Supreme Court summarily affirmed the district court order denying Defendant's motion, holding that Defendant's brief failed in all respects to comply with the rules of appellate procedure. View "Harrison v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree felony murder and aggravated child abuse but remanded to correct a sentencing error, holding that the district court did not err in denying Defendant's request for two lesser-included offense instructions and that prosecutorial misconduct did not require a new trial.On appeal, Defendant argued that the district court erred in denying his lesser-included offense instructions and that the prosecutor's statements during closing arguments constituted prosecutorial misconduct. The Supreme Court affirmed, holding that the district court did not err in denying Defendant's request for the lesser-included offense instructions and that the prosecutor did not commit misconduct. The Court, however, remanded the case to correct a sentencing error brought to its attention by the State. View "Hartley v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence seized from his home, holding that the district court did not err when it concluded that the warrantless search of Defendant's home was constitutional under the emergency aid exception to the Fourth Amendment's warrant requirement.After the district court denied his suppression motion, Defendant entered a conditional guilty plea to various drug crimes, including possession of marijuana with intent to deliver, possession of methamphetamine, and possession of marijuana. Defendant appealed the denial of his motion to suppress. The Supreme Court affirmed, holding that intrusion into Defendant's home was lawful and justified by the emergency aid exception to the Fourth Amendment's warrant requirement. View "Ferch v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of intimidating and influencing a witness in violation of Wyo. Stat. Ann. 6-5-305(a), holding that Defendant did not show that the prosecutor's comments in rebuttal closing argument or the district court's failure to instruct the jury on voluntariness constituted plain error.Specifically, the Court held (1) the prosecutor did not commit plain error during rebuttal closing argument by improperly shifting the burden of proof to Defendant or stating facts not in evidence; and (2) the district court did not plainly err in failing to instruct the jury that it had to find Defendant acted voluntarily. View "Black v. State" on Justia Law