Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court reversed Appellant’s convictions for involuntary manslaughter and reckless endangerment. On appeal, Appellant challenged the district court’s jury instructions on self-defense. The Supreme Court held (1) the justification of self-defense is available when the crime charged involves a reckless act rather than an intentional act, and therefore, the Court’s conclusion to the contrary in Duran v. State is hereby overruled; (2) the district court did not err in failing to give the jury a requested castle doctrine instruction; but (3) plain error occurred when the jury was instructed that Appellant had a duty to retreat before using deadly force. View "Haire v. State" on Justia Law

Defendant was charged in the district court with criminal contempt for violating a juvenile court order. Defendant entered a conditional no contest plea to the criminal contempt charges. Defendant then timely appealed, raising several issues. The Supreme Court reversed, holding (1) Defendant’s entire plea was invalid, but the Court exercised its discretion to convert Defendant’s appeal to a writ of review in order to clarify some of the questions of law; (2) the district court had concurrent jurisdiction over this criminal contempt action arising from conduct in juvenile court; but (3) Defendant was denied due process because the order to show cause did not contain all the elements of the charged offense, an error that was compounded when Defendant’s attorney was denied access to the juvenile court file which contained the order Defendant was accused of violating. Remanded. View "Brown v. State" on Justia Law

Defendant was convicted of second-degree sexual assault of a minor. The district court sentenced Defendant to imprisonment for six to ten years. Defendant moved for a new trial on the ground that his trial attorney was ineffective. The district court denied the motion after an evidentiary hearing. The Supreme Court affirmed the conviction and sentence, holding (1) Defendant’s attorney provided constitutionally effective assistance; and (2) the evidence was sufficient to allow rational jurors to reasonably conclude beyond a reasonable doubt that Defendant caused the victim to touch him for sexual arousal or gratification. View "Jones v. State" on Justia Law

After a jury trial, Appellant was convicted of felony exploitation of a vulnerable adult. On appeal, Appellant argued, inter alia, that the State did not present sufficient evidence to prove that the victim was a vulnerable adult. The Supreme Court affirmed, holding (1) the State presented sufficient evidence for the jury to find that the victim was a vulnerable adult as defined by statute; and (2) as regarding the jury instructions on the mental element required for conviction of felony exploitation of a vulnerable adult, the district court’s failure to edit the definition of exploitation to include only the intentional mental element did not prejudice Appellant. View "Blevins v. State" on Justia Law

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