Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court convicting Defendant of three counts of aggravated assault and battery and one count of domestic battery and sentencing Defendant to enhanced penalties under the habitual criminal statute. The court held (1) there was sufficient evidence to support Defendant’s assault and battery convictions; (2) the district court did not commit reversible error when it allowed the jury to hear testimony of domestic violence expert and evidence that the victim had been abused in prior relationships; and (3) the district court did not impose illegal sentences. View "Thompson v. State" on Justia Law

Steven McLaren challenged his convictions for five felonies stemming from a bizarre and violent encounter with his girlfriend in 2014. McLaren owned 57 cats. He and his girlfriend, Jennifer Evans, referred to the cats as their “kids” or “the kid.” In March 2014, one of Mr. McLaren’s exotic Savannah kittens, Cameo, was sick, so he and Evans took it to a veterinary clinic for treatment. McLaren testified that he had injected “somewhere between a quarter and a third of a gram” of methamphetamine right before he noticed Cameo was ill, had not slept for days, and had been experiencing hallucinations since the night before. He was under the impression that Evans was attempting to harm or kill the kitten. After taking the kitten to the vet, McLaren and Evans drove around for a time. Though nothing seemed out of the ordinary at that time, McLaren came to a complete stop in the southbound lane in front of an oncoming Pepsi truck. Evans attempted to get out of the truck, but he pulled her by her hair back into the truck and locked the doors, telling her that her “kids deserved a better mother” and that she “was going to die today.” The Pepsi truck swerved around them, and McLaren turned off Highway 191, onto Wild Horse Loop. As he drove down Wild Horse Loop, Evans fought with McLaren and continued to attempt to get out, kicking the truck into park several times. McLaren also continued to hit and punch Evans; he grabbed her throat and forced her to the floorboard of the truck. At some point, McLaren opened the passenger door and Evans fell. She testified that McLaren stood over her, pulled her head to the left and the right, “trying to rip my head off,” and then let go. As soon as McLaren released her, Evans got up and ran toward Highway 191, where a truck stopped to assist her. When Evans arrived at the emergency room, she had two lacerations on her head and numerous bruises. Appealing his felonies, McLaren argued the trial court violated his due process rights when it failed to order a third competency evaluation and when it allowed defense counsel to assert a plea of not guilty by reason of mental illness (NGMI) against his will. He also argued the jury instructions contained structural error because they did not require the State to prove he did not act in a sudden heat of passion to establish attempted second-degree murder and that the trial court abused its discretion when it denied defense counsel’s motion for mistrial after McLaren’s outburst during trial. The Wyoming Supreme Court concluded that, while the trial court did not improperly fail to order a competency hearing, it violated McLaren’s due process rights when, in spite of McLaren’s numerous declarations that he did not wish to proceed with the NGMI plea, it allowed defense counsel to assert the plea at trial. View "McLaren v. Wyoming" on Justia Law

A jury convicted appellant Donald Dean Foltz, Jr. of first-degree murder and the district court sentenced him to life without the possibility of parole. Foltz was accused of child abuse towards his girlfriend’s two-year-old son. Foltz appealed his conviction, arguing the district court erred when it denied his motion for judgment of acquittal because he contended the evidence was insufficient to support the charged against him. After review of the trial court record, the Wyoming Supreme Court found no reversible error and affirmed Foltz’s conviction. View "Foltz, Jr. v. Wyoming" on Justia Law

The Supreme Court reversed Appellant’s conviction, rendered after a jury trial, for forgery, holding that there was insufficient evidence to support a conviction under the specific subparagraph of the forgery statute that Appellant was charged with violating.On appeal, Appellant argued that, to be convicted of forgery under subparagraph (ii) of the forgery statute, the “transfer” must cause the “writing” to “purport to be the act of another” and that the State never established the causal connection in this case. The Supreme Court remanded with instructions to enter a judgment of acquittal, holding (1) in the statutory phrase “transfers any writing so that it purports to be the act of another, the transfer must cause the writing to purport to be the act of another; and (2) applying this interpretation to the facts of this case, the evidence presented by the State was insufficient to support Appellant’s conviction. View "Riddle v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant, after a jury trial, of one count of immodest, immoral or indecent liberties with a minor and three counts of second-degree sexual abuse of a minor. Defendant appealed, arguing, among other things, that the indecent liberties charge was duplicitous in that it alleged a single charge based on a course of conduct occurring during a twenty-eight month period. The Supreme Court held (1) Defendant waived any duplicity defects by failing to object; and (2) the district court did not abuse its discretion in determining that a single question asked by the prosecution, while potentially in violation of a pretrial order requiring notice to the trial court before inquiring into a specific area of facts, did not prejudice Defendant. View "Triplett v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of strangulation of a household member, in violation of Wyo. Stat. Ann. 6-2-509(a)(i). The court held (1) contrary to Defendant’s argument on appeal, the prosecutor did not commit misconduct by withholding exculpatory information from the defense in violation of Brady v. Maryland, 373 U.S. 83 (1963); and (2) the evidence presented at trial was sufficient to sustain Defendant’s conviction of strangulation of a household member because there was sufficient evidence to support the conclusion that pressure was applied to the victim’s throat or neck and that any bodily injury was caused by impeding breathing or circulation. View "Davis v. State" on Justia Law

Res judicata barred Appellant from bringing this claim challenging the district court’s denial of his motion to correct an illegal sentence.Appellant pled guilty to burglary, felony larceny, and other crimes. Appellant later filed a motion for sentence reduction. The motion was denied. Appellant then filed a motion for sentence modification, which was also denied. Thereafter, Appellant filed a motion to correct an illegal sentence, arguing that the sentences he received for two crimes should have merged under double jeopardy principles because “the exact same conduct perpetrated against the same officer” was used to prove both crimes. The district court denied the motion. The Supreme Court affirmed, holding that Appellant failed to present any facts or circumstances demonstrating good cause for not raising his double jeopardy claim in earlier proceedings and, therefore, Appellant’s claim was barred by res judicata. View "Goetzel v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Appellant of attempted second-degree murder. The court held (1) there was no plain error or cumulative error in the district court’s instructions to the jury regarding sudden heat of passion, the definition of “malice” in the context of first-degree murder, the definition of “malice” in the context of second-degree murder, an aggressor’s right to use self-defense, and the duty to retreat before asserting the right of self-defense; and (2) the district court did not abuse its discretion by instructing the jury on the definitions of both “malice” and “maliciously.” View "Schmuck v. State" on Justia Law

For the reasons outlined in Barrera v. State, 403 P.3d 105 (Wyo. 2017) and those set forth in this opinion, the Supreme Court affirmed Defendant’s felony conviction for taking a controlled substance into a jail. The court held (1) the district court did not err in concluding that Defendant’s violated Wyo. Stat. Ann. 6-5-208 when he took a controlled substance into the county jail after being arrested; and (2) given the absence of citation to any pertinent authority, the court declined to reach the merits of Defendant’s argument that the district court and the State violated the Fifth Amendment prohibition against self-incrimination. View "Farnsworth v. State" on Justia Law

The Supreme Court reversed Appellant’s conviction for aggravated assault entered after a jury trial. The district court sentence Appellant to life in prison. The Supreme Court held (1) the prosecutor’s failure to comply with the court’s discovery order constituted misconduct; (2) the district court abused its discretion in denying Appellant’s motion to restrict witness testimony; (3) the prosecutor committed misconduct during closing argument; (4) Appellant was denied due process of law because he was required to wear a leg brace in the presence of the jury; and (5) because of the cumulative effect of these errors, Appellant was denied a fair trial. View "Black v. State" on Justia Law