Justia Wyoming Supreme Court Opinion Summaries

While serving an eighteen to thirty-six-month sentence, Defendant escaped and kidnapped an elderly woman. Defendant entered a no contest plea to a kidnapping charge and a guilty plea to an escape charge. The district court sentenced Defendant to terms of years for both convictions, to run consecutive to each other and concurrent to his original sentence. The Supreme Court affirmed. Defendant later filed a pro se motion to correct an illegal sentence, requesting credit for time served between his arrest and his sentencing. The district court denied the motion. Defendant then filed a pro se motion seeking credit for 1,280 days, which was the same relief he sought in his motion to correct an illegal sentence. The court denied the motion. The Supreme Court affirmed, holding that res judicata prevented the Court’s review of the issue raised by Defendant. View "Majors v. State" on Justia Law

Defendant pled guilty to two counts of first degree murder and one count of larceny. Defendant was eighteen years old when he committed the crimes. At that time, the age of majority in Wyoming was nineteen. Defendant was sentenced to two consecutive sentences of life imprisonment on the murder counts. Defendant later filed a pro se motion to correct an illegal sentence under Wyo. R. Crim. P. 35, arguing that his life sentences violated the constitutional prohibition of cruel and unusual punishment. The Supreme Court affirmed, holding that Defendant’s sentence did not violate state law because the Eighth Amendment sentencing protections announced in Miller v. Alabama extend only to offenders under the age of eighteen. View "Nicodemus v. State" on Justia Law

Appellant was adjudicated a delinquent juvenile for committing a sexual offense that required him to register as an offender under the Wyoming Sexual Offender Registration Act (WSORA). Appellant later entered a conditional guilty plea to two felony counts for failing to report changes in his address, as required by the WSORA. Appellant appealed his convictions, claiming that the WSORA is unconstitutional. The Supreme Court affirmed, holding (1) the Wyoming Juvenile Justice Act does not conflict irreconcilably with the WSORA’s registry requirements for adjudicated juvenile offenders; (2) the WSORA does not violate the Wyoming Constitution’s equal protection clause; (3) Appellant failed to establish that the WSORA’s lifetime registration requirement violates his due process rights; and (4) the WSORA does not violate the ex post facto clause of the United States Constitution. View "Vaughn v. State" on Justia Law

Appellant was convicted of first-degree felony murder, aggravated burglary, and conspiracy to commit aggravated burglary. After the United States Supreme Court’s decision in Miller v. Alabama and the Supreme Court’s decision in Bear Cloud v. State, the Supreme Court vacated Appellant’s sentences for resentencing on all counts. Upon resentencing, the court sentenced Appellant to an aggregate sentence will require him to serve at least thirty-five years before he becomes parole eligible. Appellant appealed, arguing that his aggregate sentence violates constitutional protections against cruel and unusual punishment. The Supreme Court affirmed, holding (1) Appellant’s aggregate sentence is not a de facto sentence of life without the possibility of parole and does not violate the Eighth Amendment; and (2) Appellant’s aggravated burglary sentence of ten to twenty-five years is not grossly disproportionate or unconstitutional. View "Sen v. State" on Justia Law

Defendant entered a conditional guilty plea to felony possession of methamphetamine. Defendant reserved the right to challenge the denial of his motion to suppress the warrantless pat-down search of his person. On appeal, Defendant argued that the pat-down search amounted to an illegal warrantless search because there were no exigent circumstances to necessitate such a search. The Supreme Court affirmed the denial of Defendant’s motion to suppress, holding that the district court did not err in concluding that, based upon the totality of the circumstances, law enforcement was justified in conducting a warrantless pat-down search for officer safety reasons. View "Sweets v. State" on Justia Law

After a jury trial, Defendant was convicted of aggravated vehicular homicide. The district court sentenced Defendant to a term of fourteen to eighteen years in prison. Defendant appealed, arguing that the evidence presented by the State was insufficient to establish that he drove in a reckless manner, which was an essential element of felony aggravated homicide by vehicle. The Supreme Court affirmed, holding that the record contained sufficient evidence for a jury to have concluded that Defendant consciously disregarded a substantial and unjustifiable risk because he knew he was tired but continued to drive. View "Barrowes v. State" on Justia Law

After a jury trial, Defendant was convicted of one count of aggravated arson and one count of attempted first degree murder. On appeal, Defendant argued that there was insufficient evidence for the jury to conclude that he had the specific intent to kill the victim and that the district court violated his due process rights by allowing the State to call a witness to testify after failing timely to disclose agreements between the witness and the State. The Supreme Court affirmed, holding (1) the evidence was sufficient for a reasonable jury to conclude that Defendant intended to kill the victim; and (2) the State disclosed the information about the agreements prior to the trial, and the defense had the opportunity to use the evidence at trial, and therefore, there was no due process violation. View "Pearson v. State" on Justia Law

After a jury trial, Defendant was convicted of one count of felony interference with a peace officer and of operating an ATV without liability insurance or valid registration. Defendant appealed, challenging her felony interference conviction. The Supreme Court affirmed, holding that the district court did not err in (1) denying Defendant’s motion for judgment of acquittal because the evidence was sufficient to support the conviction; (2) failing to give the jury Defendant’s proffered self-defense instructions; and (3) failing to provide the jury with definitions of phrases contained in the felony interference charge. View "Mceuen v. State" on Justia Law

After a jury trial, Defendant was convicted of first degree murder. Defendant appealed, raising four issues related to his position at trial that the killing was not premeditated murder but, rather, the lesser included offense of voluntary manslaughter. The Supreme Court reversed due to structural error, holding that the jury instructions created reversible error as to the lesser included offense of voluntary manslaughter because they instructed the jury that the State had to prove beyond a reasonable doubt that Defendant acted in a sudden heat of passion, when the burden should have been to disprove that factor. Remanded for a new trial of the first degree murder charge. View "Shull v. State" on Justia Law

Defendant entered a conditional no contest plea to possession of methamphetamine with the intent to distribute. Defendant appealed, arguing that the district court erred in denying his motion to suppress and finding that Defendant consented to continued detention when law enforcement told him “he was free to leave” but continued to have [its] red and blue emergency overhead lights activated. The Supreme Court affirmed, holding that, under the totality of the circumstances in this case, a reasonable person in Defendant’s position would have felt free to decline the law enforcement officer’s request, and therefore, the contact between the officer and Defendant was consensual. View "Tibbetts v. State" on Justia Law