Justia Wyoming Supreme Court Opinion Summaries

Appellant Bruce Williams asked the Circuit Court for a copy of part of a presentence investigation report in a criminal case. The circuit court denied his request. He brought a petition for a writ of mandamus asking the district court to require that the circuit court release the records. The district court dismissed the case. He appealed, claiming a constitutional right as a member of the public to access these records. Because he did not present his constitutional arguments to the district court, the Supreme Court affirmed. View "Williams v. Tharp" on Justia Law

Defendant was convicted of four felony counts of obtaining property by false pretenses and one misdemeanor count of official misconduct. Defendant appealed, arguing that the State was required to prove that the title to the property at issue passed from Albany County to him and that the State failed to prove that it did. The Supreme Court (1) reversed the four felony convictions, holding that there was insufficient evidence to prove beyond a reasonable doubt that Defendant committed the crime of obtaining property by false pretenses, and (2) the Court declines to consider Defendant’s claim regarding the misdemeanor conviction of official misconduct because Defendant failed to provide cogent argument on this issue. View "Bohling v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of felony interference with a peace officer, one count of misdemeanor interference with a peace officer, and one count of misdemeanor simple assault. The Supreme Court affirmed, holding (1) the district court did not err in failing to give the jury Defendant’s proposed theory of defense instructions; and (2) Defendant’s Sixth Amendment right to effective assistance of counsel was not violated by trial counsel’s failure to file a motion to suppress, renew the motion for judgment of acquittal at the end of trial, and propose certain theory of defense instructions. View "Tingey v. State" on Justia Law

Defendant was convicted of felony possession of methamphetamine and possession of methamphetamine with intent to deliver. Defendant appealed his conviction on the charge of possession with intent to deliver, arguing that the district court erred when it admitted evidence of a prior drug transaction. Further, Defendant claimed that because felony possession is a lesser included offense of possession with intent to deliver, the district court erred in convicting and sentencing him on both counts. The Supreme Court reversed Defendant’s conviction for possession with intent to deliver, holding (1) the district court erroneously admitted the evidence of Defendant’s prior drug transaction; and (2) it is therefore unnecessary to consider Defendant’s second issue. View "Overson v. State" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree sexual assault and one count of battery of a household member. The Supreme Court affirmed, holding (1) trial counsel for Defendant did not provide ineffective assistance when he failed to challenge the credibility of the alleged victim; (2) Defendant failed to establish that the State committed a violation of Brady v. Maryland when the prosecutor allegedly failed to disclose exculpatory evidence relating to the alleged victim; and (3) the State presented sufficient evidence to support Defendant’s conviction for battery of a household member. View "Worley v. State" on Justia Law

After a one-day jury trial, Defendant was convicted of three counts of sexual abuse of a minor in the second degree. Defendant appealed, arguing that the district court abused its discretion when it admitted evidence that Defendant was in violation of his parole at the time of the offenses. The Supreme Court affirmed, holding that the district court did not abuse its discretion in admitting evidence relating to the terms of Defendant’s parole and his parole violations, as the district court considered the required Gleason criteria and had a legitimate basis for its conclusions. View "Vasquez v. State" on Justia Law

Defendant was charged with felony stalking. Defendant’s first jury trial ended in a mistrial. Thereafter, a second jury found Defendant guilty of felony stalking. Defendant was sentenced to a term of incarceration, suspended on the condition that Defendant complete five years of probation. Defendant appealed, arguing that his rights against double jeopardy were violated because the prosecutor forced him into moving for a mistrial. The Supreme Court affirmed, holding (1) there was no evidence in the record indicating prosecutorial intent to provoke the defense into moving for a mistrial; and (2) therefore, Defendant’s rights against double jeopardy were not violated in this case. View "Montoya v. State" on Justia Law

Defendant entered a conditional plea to a fourth offense felony DWUI charge, reserving the right to challenge the denial of his motion to dismiss. The court found Defendant guilty of his fourth DWUI offense in a ten-year period and sentenced him to two to four years, suspended in favor of supervised probation. Defendant appealed, arguing that his 2005 conviction could not be used as a prior offense because it did not occur within ten years of his present conditional guilty plea. The Supreme Court affirmed, holding that the ten-year look-back period for enhanced DWUI penalties applies from the date of the last offense, rather than the date of the last conviction. View "Ramirez v. State" on Justia Law

Appellant was charged with felony possession of methamphetamine and misdemeanor interference with a peace officer. Appellant’s appointed counsel moved to suspend proceedings pending a competency evaluation. The trial court granted the motion. After a competency evaluation and competency hearing, the court found Appellant competent, and the matter proceeded to trial. The jury found Appellant guilty of interference with a peace officer, but a mistrial was declared on the possession charge. Thereafter, defense counsel suggested that a second competency evaluation was needed. The court ultimately concluded that a second competency evaluation was not warranted. Appellant then entered an Alford plea to felony possession of methamphetamine. Appellant appealed from both convictions. The Supreme Court affirmed, holding that any alleged error in the district court’s failure to suspend proceedings and order a second competency evaluation was inconsequential. View "Marshall v. State" on Justia Law

After a jury trial, Appellant was convicted of conspiracy to deliver a controlled substance. The district court sentenced Appellant to not less than four years nor more than eight years in prison. Appellant appealed, claiming that he received ineffective assistance of counsel because “a skilled criminal defense advocate would likely be able to secure a more favorable agreement than was obtained in his current sentence.” The Supreme Court affirmed, holding that Appellant failed to establish that he was prejudiced by counsel’s alleged deficient performance, and therefore, it was unnecessary to address the deficiency prong of the ineffectiveness standard. View "McNaughton v. State" on Justia Law