Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of attempted second-degree murder and aggravated assault and battery. The district court sentenced Defendant to forty to fifty years in prison for the attempted murder and to a term of fifteen to fifty years for the aggravated assault and battery. Defendant appealed, challenging his sentences. The Supreme Court affirmed, holding (1) the cumulative sentences Defendant received upon conviction of the offenses of attempted second-degree murder and aggravated assault and battery did not offend principles of double jeopardy; and (2) the statutes under which Defendant was convicted were not unconstitutionally vague, either on their face or as applied to the facts of Defendant’s case. View "Jones v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of sexual abuse of a minor in the first degree. Defendant was sentenced to serve concurrent terms of fifteen to thirty-five years in prison. Defendant appealed, asserting that the prosecutor invaded the province of the jury by telling the jurors how to deliberate in violation of his right to a fair trial. The Supreme Court affirmed, holding (1) Defendant’s claim that the prosecutor improperly told the jury what to think was without merit; and (2) thus, Defendant failed to establish prosecutorial misconduct, and the district court did not err in overruling Defendant's objection to the prosecutor’s rebuttal argument. View "Watkins v. State" on Justia Law

After a jury trial, Defendant was found guilty of conspiracy to commit first-degree murder. Defendant was sentenced to life imprisonment. The Supreme Court affirmed, holding (1) the trial court erred when it allowed the State to play a video of an explosion of a “pipe bomb” because that video was not timely provided to defense counsel, but the error was not prejudicial; (2) the trial court abused its discretion when it allowed the State to use evidence - a bank statement - that the State did not timely provide to defense counsel, but the error was harmless; and (3) the trial court did not err in admitting character evidence under Wyo. R. Evid. 404(b) and in refusing to give a limiting instruction with regard to use of Rule 404(b) evidence. View "Brown v. State" on Justia Law

After a four-day jury trial, Defendant was found guilty of multiple counts of first degree sexual assault, battery, and unlawful contact without bodily injury. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress statements he made to a nurse during a sexual assault examination in an alleged violation of Defendant’s rights under Miranda v. Arizona; and (2) Defendant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48(b) and the Sixth Amendment to the United States Constitution. View "Tate v. State" on Justia Law

Defendant was sentenced to two life sentences according to law for crimes he committed in the 1990s. In 2015, Defendant filed a complaint against the Wyoming Board of Parole and the Wyoming Department of Corrections pursuant to the Declaratory Judgment Act, alleging various constitutional violations. The district court dismissed Defendant’s claims. The Supreme Court affirmed, holding (1) Wyo. Stat. Ann. 7-16-2016(a)(i) does not violate Defendant’s equal protection rights because there is a legitimate state interest in treating prisoners differently with respect to the statute; (2) the Wyoming Department of Corrections’ good time policy does not violate Defendant’s equal protection rights because prisoners serving life according to law and prisoners serving a term of years sentence are not similarly situated; (3) the enactment of section 7-16-205(a)(i) did not impliedly repeal Wyo. Stat. Ann. 7-13-402(a); (4) the Wyoming Board of Parole did not violate the doctrine of separation of powers by enacting policies governing the commutation application procedure; (5) Defendant’s due process rights were not violated by the amendment to the commutation application procedure; and (6) the Wyoming Board of Parole’s amendment to the commutation application procedure did not violate Defendant’s constitutional protection against ex post facto laws. View "Bird v. Wyoming Board of Parole" on Justia Law

After a jury trial, Appellant was found guilty of stalking. The district court sentenced Appellant to a term of three to five years in prison. Appellant appealed, arguing that the district court abused its discretion by not granting a mistrial for a violation of an order in limine concerning Wyo. R. Evid. 404(b) evidence and by imposing a discovery sanction that precluded the State from introducing untimely disclosed text messages but allowing the jury to hear testimony about them. The Supreme Court affirmed, holding that the district court did not err in not granting a mistrial and in not imposing a stiffer sanction for the discovery violation. View "Salinas v. State" on Justia Law

After a jury trial, Defendant was convicted of first degree arson for setting a fire in a Walmart store. Defendant was sentenced to a term of ten to eighteen years in prison. Defendant appealed, arguing that there was insufficient evidence to support his conviction because he was intoxicated at the time he set the fire. Therefore, Defendant argued, he should have only been charged with third degree arson. The Supreme Court affirmed Defendant’s conviction and sentence, holding that the State proved that, despite Defendant’s intoxication, Defendant acted maliciously with intent to destroy or damage an occupied structure, and therefore, there was sufficient evidence to support the conviction. View "Harnden v. State" on Justia Law

After Defendant was placed on probation, the State filed a petition to revoke his probation on the grounds that Defendant violated the conditions of his probation. The district court determined that Robinson had violated the terms of his probation because he failed to prove that he maintained employment and repeatedly failed to submit to a polygraph. Defendant appealed, arguing that the district court erred in both the adjudicatory and dispositional phases of the probation revocation process. The Supreme Court affirmed the revocation and imposition of Defendant’s sentences, holding that the district court did not err either in the adjudicatory or the dispositional phases of the probation revocation process. View "Robinson v. State" on Justia Law

After a jury trial, Defendant was convicted of seven counts of felony forgery and one count of misdemeanor theft. Defendant appealed, alleging that her prosecution was motivated by prosecutorial vindictiveness, that she received ineffective assistance of counsel, that the prosecutor argued facts not in evidence during closing arguments, that the district court erred by failing to provide supplemental instructions to the jury, and that the evidence was insufficient to support the convictions. The Supreme Court affirmed, holding (1) there was no plain error in Defendant’s claim of vindictive prosecution, in Defendant’s claim of prosecutorial misconduct, or in the district court’s refusal to provide supplemental instructions to the jury; (2) Defendant’s right to effective assistance of counsel was not violated; and (3) Defendant’s convictions were supported by sufficient evidence. View "Mraz v. State" on Justia Law

Appellant, an inmate at Wyoming’s medium-security correctional facility in Torrington, wrote a letter to the warden asking to inspect certain public records of that institution. The institution’s employees provided him with some, but not all, of the requested documents. Appellant subsequently filed a complaint for order of enforcement and request to show cause, asserting that because the institution’s employees had not timely completed their efforts to fulfill his records requests they effectively refused to comply under the law. The institution subsequently made available to Appellant the remainder of the requested records. Thereafter, the district court dismissed Appellant’s complaint. The Supreme Court affirmed, holding that the district court (1) properly confined the scope of its review to that permitted by the Wyoming Public Records Act, (2) properly found that Appellees fully complied with Appellant’s records request, and (3) properly received information regarding the warden’s initial response to that request. Further, there was no preemption of the WPRA. View "Guy v. Lampert" on Justia Law