Justia Wyoming Supreme Court Opinion Summaries

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

A detective from the Cheyenne Police Department investigated a break-in and vehicle theft at Swagger Construction on October 10, 2023. The project manager reported missing items, including a company truck and flatbed trailer, and noted "Claim Ins" written on a calendar. The security footage was also missing. The detective later found the stolen trailer on someone's property, loaded with tools, equipment, and a Jeep registered to Andrew Michael Hanson. Hanson was arrested for leaving the scene of an accident while driving the stolen truck. The detective found the missing security footage in the truck, which showed Hanson entering the building through a window and taking items.The State charged Hanson with burglary and felony theft. At trial, the State presented testimony from the arresting officer, the project manager, and the detective, and introduced the security footage as evidence. Hanson moved for a judgment of acquittal, arguing insufficient evidence that he acted without authority. The district court denied the motion, and the jury found Hanson guilty on both counts. He was sentenced to two to four years of incarceration, suspended in favor of three years of probation.The Wyoming Supreme Court reviewed the case, focusing on whether the State presented sufficient evidence for the jury to conclude beyond a reasonable doubt that Hanson acted without authority. The court held that the State provided strong circumstantial evidence, including the project manager's testimony, the security footage, and the detective's findings. The court affirmed Hanson's convictions, concluding that the evidence was sufficient for the jury to reasonably infer that Hanson acted without authority. View "Hanson v. State" on Justia Law

Timothy Duke was identified as one of the burglars involved in the theft of numerous items from three properties owned by Joseph Walsh in Cheyenne. The stolen items included cash, collectible coins, firearms, trade tokens, and antique police badges. Following an investigation, police recovered some of the stolen items from Duke's home, vehicle, and trailer. Duke was charged with theft over $1,000 and aggravated burglary with a deadly weapon. He pled guilty to the aggravated burglary charge as part of a plea agreement, and the theft charge was dismissed. Duke agreed to pay restitution jointly and severally with his co-defendants.The District Court of Laramie County held a restitution hearing where Walsh testified about the stolen items and their estimated values. The court also considered a presentence investigation report and victim impact statements. The court ordered Duke to pay $507,000 in restitution, finding the State had provided sufficient evidence to support the amount claimed.The Supreme Court of Wyoming reviewed the case to determine if the district court abused its discretion in setting the restitution amount. The court found that Walsh's testimony, the State's supporting exhibits, and the presentence investigation report provided a reasonable basis for the restitution award. Walsh's detailed testimony about the stolen items and their values, corroborated by the presentence investigation report and victim impact statements, was deemed credible and sufficient.The Supreme Court of Wyoming affirmed the district court's restitution order, concluding that the district court did not abuse its discretion and that the restitution amount was supported by sufficient evidence. View "Duke v. State" on Justia Law

Jeremy Clay was arrested for traffic violations and drug offenses on September 23, 2023, and later charged with failure to register as a convicted sex offender. He pled guilty to the failure to register charge and was sentenced to three to five years of incarceration, with all but thirty days suspended, followed by three years of supervised probation. Clay did not appeal the original judgment and sentence. On June 28, 2024, the State filed a petition to revoke his probation, alleging violations including failure to contact his probation agent, leaving Wyoming without permission, and failing to make a required payment. Clay admitted to the violations at a hearing, and the court revoked his probation, sentencing him to nine months in jail, suspended in favor of a split sentence of seventy-two days in jail followed by three years of supervised probation. He timely appealed the probation revocation order.The Wyoming Supreme Court reviewed the case. Clay's appeal focused on alleged violations of his rights during the original criminal proceedings, including claims of Fourth Amendment violations, prosecutorial misconduct, and ineffective assistance of counsel. The State argued that the court lacked jurisdiction to review these claims because Clay did not appeal the original judgment and sentence within the required thirty days.The Wyoming Supreme Court affirmed the district court's order, applying res judicata principles. The court held that Clay's claims were barred by res judicata because he could have raised them in a direct appeal of the original judgment and sentence but failed to do so. The court determined that the parties, subject matter, and issues were the same in both the original criminal proceeding and the probation revocation, and Clay did not show good cause for failing to raise the issues earlier. As a result, Clay was not entitled to relief from the court. View "Clay v. State" on Justia Law