Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the ruling of the district court concluding that the probationary portion of a sentence imposed by the municipal court upon Respondent was illegal. Respondent entered a no contest plea to violating Casper Municipal Code 5.08.370(A) and (B). The municipal court sentenced Respondent to, in addition to a fine, six months of unsupervised probation. The district court reversed the municipal court’s sentence, concluding that it was illegal because the Casper ordinances governing the penalty for the possession of alcohol by a minor expressly limited that penalty to a fine and did not provide for a potential penalty of incarceration. The Supreme Court agreed, holding that the district court did not err in concluding that when no confinement is expressly authorized as a punishment for a particular offense, a sentencing court also lacks the authority to impose a period of probation upon a conviction for such an offense. View "City of Casper v. Simonson" on Justia Law

The Supreme Court affirmed Defendant’s aggravated assault and battery conviction and reversed and remanded for acquittal on Defendant’s battery conviction, holding (1) the trial court did not commit plain error or deny Defendant’s Sixth Amendment right to confront witnesses against him when it allowed the emergency medical technician and the physician who treated the victim to testify regarding several statements the victim made to them because the statements were not testimonial; and (2) Defendant’s battery conviction was not supported by sufficient evidence because the jury could not have reasonably concluded that the victim suffered bodily injury when Defendant hit him. View "Villarreal v. State" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence collected pursuant to a search warrant, concluding that the police officer’s affidavit used to obtain the search warrant established probable cause sufficient to justify the issuance of the search warrant.Defendant entered a conditional guilty plea to charges of delivery of a controlled substance and possession of a controlled substance. On appeal, Defendant argued that the affidavit was deficient, that the circuit court improperly issued the warrant, and that the search violated Defendant’s rights under the Fourth Amendment to the United States Constitution and Wyo. Const. art. I, 4. The Supreme Court held that the affidavit established probable cause supporting the issuance of the search warrant. View "Fosen v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of one count of aggravated robbery, holding that the district court did erred in ordering Defendant to make pretrial disclosure of information requested by the State pursuant to Wyo. R. Evid. 404(b) because a defendant is not required to make a pretrial disclosure of such information. In addition, the district court erred in limiting cross-examination by defense counsel as a sanction for Defendant’s failure to disclose such evidence. Ultimately, however, the limitation placed on Defendant’s cross-examination was harmless beyond a reasonable doubt given the strength of the State’s case against Defendant. View "Broussard v. State" on Justia Law

After a jury trial, Defendant was convicted of five counts of sexual assault and sexual abuse of a minor. Defendant appealed, arguing that he was denied his right to a fair trial due to the cumulative error of three instances of prosecutorial misconduct during the prosecutor’s closing argument. The Supreme Court affirmed, holding (1) the prosecutor committed misconduct by attempting to define reasonable doubt for the jury; (2) the prosecutor committed misconduct by suggesting that Defendant carried any burden of proof; but (3) Defendant was not cumulatively prejudiced by the prosecutor’s statements to such an extent that his trial was anything other than fair and impartial. View "Hamilton v. State" on Justia Law

Defendant pleaded no contest to second-degree murder. After Defendant was sentenced, the State and Defendant filed a joint motion to correct an illegal sentence, agreeing that Defendant had not been sentenced in accordance with the terms of his plea agreement. Dissatisfied with his stipulated sentence amendment, Defendant filed a motion to vacate an illegal sentence and a motion to withdraw his no contest plea. The district court denied the motion. The Supreme Court affirmed, holding (1) the district court lacked jurisdiction to consider Defendant’s post-sentence motion to withdraw his guilty plea because Defendant’s post-sentence motion was untimely; and (2) accordingly, this court lacked jurisdiction to consider Defendant’s appeal. View "Sanchez v. State" on Justia Law

Defendant, who received state and federal convictions for drug and firearm offenses, filed a motion for a sentence reduction, asking that his aggregate state sentence be altered to run concurrently with the federal sentence he was then serving so that he might be eligible to participate in his federal facility’s drug treatment program earlier. The district court denied the motion without a hearing, concluding that no showing had been made pursuant to W. R. Crim. P. 35(b) to justify or require a reduction of Defendant’s sentence. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in declining to run the Wyoming sentence concurrently with the federal sentence without holding a hearing; and (2) as to Defendant’s remaining issues on appeal, they were not raised in the district court, and Defendant now offered no cogent argument or pertinent authority in support of his position. View "Simms v. State" on Justia Law

In 1995, Appellant pled guilty to second-degree murder. In 2016, Appellant filed the two motions at issue in this appeal. The first motion was a request that the district court order the Wyoming Department of Corrections to provide a copy of all of Defendant’s records at the State’s expense. The second motion was “time line…on how much time the Defendant would have to serve” and an order requiring that he receive parole. The district court denied both motions. The Supreme Court dismissed the appeal, holding that the district court had no jurisdiction to consider either of Appellant’s motions because appellant provided no cogent argument or relevant authority demonstrating that the district court had jurisdiction to grant the relief he requested. The court further ordered Appellant to show cause why the filing restrictions stated in this opinion should not be imposed. View "Barela v. State" on Justia Law

Appellant appealed his convictions for kidnapping and misdemeanor theft of a cell phone, arguing that there was insufficient evidence to support the convictions. The Supreme Court affirmed, holding (1) a reasonable jury could have found from the facts presented that the time the victim was forced to spend in her house with Appellant was sufficient to constitute confinement within the meaning of Wyoming’s kidnapping statute; and (2) there were sufficient facts for a jury to reasonably conclude that each of the elements of misdemeanor theft relating to the taking of an Apple iPhone was proven beyond a reasonable doubt. View "Dockter v. State" on Justia Law

A jury found Defendant guilty of one count of aggravated assault and battery after he hit Sam Trujillo with his vehicle. The trial court sentenced Defendant to two to four years in prison. The Supreme Court affirmed Defendant’s conviction, thus rejecting Defendant’s contention that his conviction should be reversed due to the ineffective assistance of counsel he received at trial. The court held that trial counsel was not ineffective in failing to request either an accident instruction or a defense of others jury instruction. View "Starr v. State" on Justia Law