Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s conviction, rendered after a jury trial, of one count of domestic battery and one count of strangulation of a household member for attacking his girlfriend. On appeal, Defendant argued that the district court violated his constitutional right of confrontation when it refused testimony about the victim’s prior relationship from the sister of the victim’s former boyfriend. The Supreme Court disagreed, holding that the district court did not err by excluding the testimony under the rules of evidence and the court’s case law interpreting them. View "Garland v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of two counts of sexual abuse of a minor in the first degree and two counts of sexual abuse of a minor in the second degree. On appeal, Defendant argued that the district court erred in its instructions to the jury on the elements of the crime of sexual abuse of a minor in the first degree. In affirming, the Supreme Court held that the district court improperly instructed the jury on the two counts of sexual abuse of a minor in the first degree but that the errors did not prejudice Appellant. View "Nunamaker v. State" on Justia Law

Defendant was sixteen years old when he committed the crimes at issue in this case. The Supreme Court affirmed Defendant’s convictions of one count of first-degree murder, one count of aggravated assault and battery, and ten counts of attempted aggravated assault and battery but reversed Defendant’s sentence and remanded for resentencing. The court held (1) the district court did not abuse its discretion when it denied Defendant’s motion to transfer the proceedings to juvenile court; (2) there were some errors in the jury instructions, but the errors were not prejudicial either individually or cumulatively; (3) the prosecutor’s victim impact statements during closing arguments were improper but not prejudicial; (4) there was sufficient evidence to support the attempted assault and battery charges; (5) Defendant’s aggregate sentence did not deprive the parole board of its statutory authority to consider parole of juveniles after twenty-five years; (6) Defendant’s sentence for murder and aggravated assault of the same victim did not violate double jeopardy; but (7) Defendant’s aggregate sentence violated the Eighth Amendment because it was a de facto life without parole sentence. View "Sam v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for felonious restraint, rendered after a jury trial. The district court sentenced Defendant to incarceration for a period of not less than fifteen months nor more than forty-eight months. On appeal, Defendant argued that the district court abused its discretion when it declined to instruct the jury on the term “bodily injury” and that there was insufficient evidence to establish that the unlawful restraint exposed the victim to a risk of serious bodily injury. The Supreme Court held (1) the district court did not abuse its discretion when it rejected Defendant’s proposed instruction on the definition of “bodily injury”; and (2) there was sufficient evidence to establish the elements of felonious restraint. View "Hurley v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of first-degree felony murder but vacated Appellant’s sentence for the aggravated burglary conviction, the underlying felony. The court held (1) the district court did not err in refusing to instruct the jury that self-defense could be raised as a defense to a charge of felony murder; (2) the district court did not abuse its discretion in denying Appellant’s request to instruct the jury on the definition of the phrase “in the perpetration of” as used in Wyo. Stat. Ann. 6-2-101; but (3) the district court’s issuance of convictions for felony murder and aggravated burglary, the underlying felony, violated protections against double jeopardy. View "Schnitker v. State" on Justia Law

The Supreme Court affirmed the convictions of Appellants, Michael Tibbets and Donna Gifford, each of three counts of child abuse in relation to injuries inflicted upon their children. The district court sentenced Appellants to terms of three to five years for each count, to be served consecutively, but suspended all but Appellants’ first year of confinement in favor of supervised probation. On appeal, Appellants argued that the Sate produced insufficient evidence to support the convictions. The Supreme Court disagreed, holding that the State produced sufficient evidence to prove beyond a reasonable doubt that Appellants recklessly caused mental injury to their children, which was sufficient to sustain their convictions for child abuse under Wyo. Stat. Ann. 6-2-503(b)(ii). View "Gifford v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions of one count of first degree sexual abuse of a minor and one count of second degree sexual abuse of a minor but reversed and remanded for resentencing on Defendant’s first degree sexual abuse conviction. The court held (1) the district court did not err when it denied Defendant’s motion to suppress his statements to law enforcement because Defendant did not make an adequate request for counsel; (2) the district court violated a clear and unequivocal rule of law by allowing the police interview of Defendant to be played to the jury, but Defendant was not prejudiced; (3) the district court did not abuse its discretion when it quashed a subpoena duces tecum without conducting an in camera review of the material; and (4) Defendant was entitled to be resentenced on Count II because it violated Wyo. Stat. 7-13-201. View "Hathaway v. State" on Justia Law

Appellant pled guilty to third-degree sexual abuse of a minor. The district court accepted the guilty plea and imposed five years of supervised probation. Appellant later filed a motion to withdraw his guilty plea, arguing that he had received ineffective assistance of counsel and was prejudiced because he would not have pled guilty were it not for counsel’s deficient performance. The district court denied the motion. The Supreme Court affirmed, holding that counsel’s performance was not deficient, and therefore, the district court did not abuse its discretion in denying Appellant’s motion to withdraw his guilty plea. View "Berger v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of theft, rendered after a jury trial. On appeal, Defendant argued that the prosecutor committed misconduct when he mentioned Defendant’s race during rebuttal closing arguments. Specifically, Defendant argued that, in doing so, the prosecutor attempted to appeal to the racial bias of the jury. The Supreme Court held (1) when the prosecutor commented on Defendant’s race, he was doing so in response to defense counsel’s suggestion that race was an issue; and (2) therefore, there was no prosecutorial misconduct committed in this case and no plain error committed by the trial court. View "Cole v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions for three counts of first-degree sexual abuse of a minor and one count of second-degree sexual abuse of a minor. On appeal, Defendant argued that the district court abused its discretion in denying his motion for new trial based on the admission of photographs depicting the child victim’s vagina, on the court’s refusal to play Defendant’s entire law enforcement interview, on improper opinion testimony from a nurse practitioner, and on the prosecutor’s comment during closing argument. The Supreme Court held (1) the district court properly denied Defendant’s motion for new trial; and (2) because Defendant failed to establish any underlying errors or prejudice from any alleged errors, his claim of cumulative error failed. View "Carrier v. State" on Justia Law