Justia Wyoming Supreme Court Opinion Summaries

Appellant pled no contest to charges of larceny, burglary, and possession of a controlled substance with intent to deliver. Appellant later filed a motion to correct an illegal sentence, arguing that his sentence was illegal because he had not received credit for the time he spent in the county jail after he was sentenced but before he was transferred to a Wyoming Department of Corrections facility. The district court denied the motion. The Supreme Court affirmed, holding that Appellant’s claim was not one properly raised in a motion to correct an illegal sentence under Wyo. R. Crim. P. 35. View "Candelario v. State" on Justia Law

Defendant stole a car in Thermopolis and drove it toward Colorado. Defendant was arrested and jailed in Colorado. The State of Wyoming charged Defendant in Laramie County with receiving stolen property and in Hot Springs County with larceny. The State filed detainers in Colorado pursuant to the Interstate Agreement on Detainers (IAD), and Defendant requested deposition of the charges against him in both counties. Because the State failed to try Defendant within the 180-day period required by the IAD, the Laramie County charges were dismissed with prejudice. The State again failed to timely bring Defendant to trial, and the Hot Springs County charge was dismissed with prejudice. Defendant was then transported back to Colorado. The State then filed another charge against Defendant in Hot Springs County for receiving stolen property. A jury convicted Defendant. The Supreme Court reversed, holding that the dismissal of the Laramie County charge with prejudice barred the State from charging Defendant with the same crime in Hot Springs County. View "Webster v. State" on Justia Law

After a jury trial, Appellant was convicted of one count of burglary. Appellant was sentenced to eighteen to thirty-six months in prison. The Supreme Court affirmed, holding (1) Appellant failed to meet his burden of proving that he was prejudiced by the admission of what he contended was uncharged misconduct evidence; and (2) the State did not commit prosecutorial misconduct rising to the level of plain error in its closing argument, as it could not be said Defendant would have received a more favorable verdict if the comment had not been made. View "Wiese v. State" on Justia Law

After a jury trial, Defendant was convicted of driving under the influence of alcohol. During the trial, the district court allowed the State to introduce expert testimony involving retrograde extrapolation to prove that Defendant’s blood alcohol level was above the legal limit of 0.08 percent while he was driving on the night in question. Defendant did not object to the admission of the testimony at trial. On appeal, Defendant challenged the admission of the retrograde extrapolation evidence. The Supreme Court affirmed, holding that Defendant failed to establish that he was prejudiced by admission of the challenged evidence. View "Young v. State" on Justia Law

Defendant was charged with conspiracy to deliver a controlled substance, unlawful possession of a controlled substance, and obstruction of a peace officer. Defendant filed a motion to suppress, arguing that the stop of his vehicle was unlawful. The district court denied the motion, concluding that the traffic stop and investigatory detention of Defendant were reasonable. Defendant entered a conditional guilty plea to all three charges. The Supreme Court affirmed, holding that the district court did not err when it denied Defendant’s motion to suppress evidence, as the information available to the officer at the time he made the traffic stop could give rise to a reasonable suspicion of criminal activity. View "Jennings v. State" on Justia Law

In 1995, Appellant pled guilty to second-degree murder and was sentenced to twenty-eight years to life. In 2015, Appellant filed a pro se motion to correct an illegal sentence, claiming that his sentence was illegal because the district court failed to provide a firearms disqualification advisement at the time of sentencing. The district court denied the motion, concluding (1) the advisement statute, Wyo. Stat. Ann. 7-11-507, was not applicable to Appellant’s case because the statute was not enacted until 2009; and (2) Appellant’s sentence was permitted under Wyo. Stat. Ann. 6-2-104. Appellant appealed, presenting several claims in support of his contention that his sentence was illegal. The Supreme Court affirmed, holding that the district court did not err in its decision to deny Appellant’s motion to correct illegal sentence. View "Barela v. State" on Justia Law

After a jury trial, Defendant was convicted of possessing small amounts of morphine and methamphetamine. The offenses were felonies due to Defendant’s prior controlled substance convictions. The district court sentenced Defendant to concurrent sentences of two to five years in prison. The Supreme Court affirmed the convictions and sentence, holding (1) Defendant’s counsel was not ineffective for failing to move to suppress the evidence found during the warrantless search of Defendant’s backpack; (2) the evidence was sufficient to support Defendant’s convictions; and (3) the district court properly rejected Defendant’s request for an additional instruction on constructive possession. View "Lemley v. State" on Justia Law

After a jury trial, Defendant was convicted of one count child endangering/obscene act. The conviction arose from Defendant’s act of exposing himself to an eleven-year-old girl and then masturbating. Defendant appealed, arguing (1) the trial court erred when it refused to instruct the jury on the definition of the term “presence” as it is used in the charging statute, Wyo. Stat. Ann. 6-4-403(b)(iii), and (2) the district court improperly admitted evidence of Defendant’s prior bad acts in the form of court documents rather than testimony. The Supreme Court reversed, holding (1) the trial court did not err in refusing to admit the proposed jury instruction; but (2) the trial court abused its discretion when it admitted the court documents to show prior bad acts evidence, and Defendant was prejudiced by the admission of those exhibits. Remanded for a new trial. View "Dougherty v. State" on Justia Law

Appellant Justin Sadler was convicted by jury of aggravated assault. Prior to his state trial, Sadler was convicted in federal court of being a felon in possession of a firearm, based on the same circumstances that gave rise to his state charges. The State indicated that it would seek to admit this prior conviction under W.R.E. 609(b) if Sadler testified. The district court reserved ruling on whether Sadler’s federal conviction would be admissible, however, it observed that if Sadler denied possessing the firearm, the probative value of the prior conviction “escalates off the charts.” Sadler elected not to testify at trial. On appeal of his state charges, Sadler challenged the propriety of the district court’s comments, claiming that the court improperly chilled the exercise of his constitutional right to defend himself by testifying on his own behalf. Because he did not preserve the issue he raised on appeal, the Wyoming Supreme Court affirmed. View "Sadler v. Wyoming" on Justia Law

Appellant Marvin Clay challenged the denial of his motion to suppress evidence supporting a conviction for driving under the influence of alcohol. The officer testified that he made the stop because the car did not have any license plates displayed. All he could see at that point was a white piece of paper in the upper left corner of the rear window, which was heavily tinted. Because he was unable to verify that the white piece of paper was a document which would allow Appellant to operate the vehicle temporarily, the officer approached the car and talked to him. He asked about the paper and if there was a bill of sale. The document in the window turned out to be a title, but more than forty-five days had elapsed since the transfer, and the officer could not tell if it was notarized, both of which were required for operation of the vehicle to be legal. Appellant said there was a bill of sale, and opened his wallet and started thumbing through it for that document, but he never pulled anything out. Appellant could not provide a driver’s license or proof of insurance either. Within the first minute of Appellant slowly flipping through his wallet, the officer observed signs of possible intoxication. A DUI Task Force officer was called, and three field sobriety tests were performed. Appellant "performed poorly" on all three. Appellant was ultimately charged, inter alia, with Driving Under the Influence, Fourth Offense. On appeal, Appellant argued that his detention was improperly expanded beyond the scope of the initial traffic stop, and that the evidence used to support the DUI arrest was discovered only after the unnecessary contact and therefore ought to have been suppressed. Finding no error in the trial court's decision, the Supreme Court affirmed. View "Clay v. Wyoming" on Justia Law