Justia Wyoming Supreme Court Opinion Summaries

Appellant Jeffery Lafferty was incarcerated awaiting trial for 811 days before pleading guilty to two counts of taking indecent liberties with his minor stepdaughter. After balancing the required factors, the district court concluded that the delay in bringing Lafferty to trial was reasonable and did not impair his right to a fair trial. On appeal, he argued his constitutional right to a speedy trial was violated. A review of the record revealed to the Wyoming Supreme Court that much of the delay was the result of appellant's own actions, "which in the aggregate caused his case to go on the circuitous journey it did." As such, the Court found no violation of appellant's constitutional right to a speedy trial and affirmed his convictions. View "Lafferty v. Wyoming" on Justia Law

In 2011, Defendant was arrested for the 1972 rape and murder of Sharon Reher. After a jury trial, Defendant was acquitted of rape and murder but convicted of attempted rape. Defendant appealed, arguing that the district court abused its discretion when it denied his motion to exclude results of touch DNA testing and that there was insufficient evidence to support his conviction. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it concluded that the touch DNA evidence was not so unreliable that it ought to be excluded from the jury’s consideration; and (2) there was sufficient evidence to support Defendant’s conviction and the district court’s denial of Defendant’s motions for judgment of acquittal. View "Bean v. State" on Justia Law

Defendant pled guilty to three counts of second-degree sexual assault and was sentenced to three consecutive sentences of eight to sixteen years. The district court credited ninety-nine days of presentence confinement toward Defendant’s first sentence. Defendant later filed a motion to correct an illegal sentence, arguing that he should have been credited for time served against all three consecutive sentences. The district court denied the motion. The Supreme Court affirmed, holding (1) while res judicata would normally apply to bar Defendant’s motion, this was an appropriate case to consider the application of presentence confinement credit to consecutive sentences; (2) when consecutive sentences are ordered, the presentence credit for time served should be applied in such a way that the defendant receives credit against the total time of incarceration; and (3) Defendant’s aggregate sentence in this case was legal. View "Palmer v. State" on Justia Law

The State charged Appellant with aggravated assault and battery. At trial, Appellant claimed he had acted in self-defense. After a three-day trial, the jury found Appellant guilty. Appellant subsequently filed a motion for a new trial based on newly discovered evidence. Following a hearing on Appellant’s motion for a new trial, the district court denied the motion, concluding that Appellant had not demonstrated that the evidence was so material that it would probably produce a different verdict if a new trial was granted and that the evidence did not provide proper grounds for granting a new trial. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in denying Appellant’s motion for a new trial. View "Emerson v. State" on Justia Law

Defendant entered a plea of no contest to one count of delivery of methamphetamine. In 2011, the district court revoked Defendant’s probation and entered judgment on her no contest plea. The court sentenced Defendant to a term of years in prison but suspended the sentence and placed her on supervised probation. Defendant’s probation was set to expire in February 2014, but in January 2014, a probation agent filed a petition to extend her probationary term to August 2015. Defendant filed a document agreeing to the extension but was not represented by counsel. The district court subsequently entered an order extending probation. In February 2015, the State petitioned to revoke Defendant’s probation. Defendant argued that the probation extension had not been handled properly and if the probation extension had not been entered, Defendant’s probation would have expired prior to the February 2015 revocation hearing. The district court ruled that Defendant did not have the right to counsel during her probation extension proceeding. The court then revoked Defendant’s probation. The Supreme Court affirmed, holding that Defendant’s challenge to the probation extension entered more than one year before her probation was revoked was time barred. View "Poignee v. State" on Justia Law

Defendant pleaded guilty to misdemeanor breach of peace and misdemeanor interference with a peace officer. Two days later, the State filed an information charging Defendant with felony interference with a peace officer arising out of the same events as those underlying his misdemeanors convictions. Defendant entered an unconditional plea of no contest to a reduced charge of misdemeanor interference. Defendant appealed, arguing that his second misdemeanor conviction violated his double jeopardy protections. The Supreme Court affirmed, holding (1) Defendant did not waive his double jeopardy claim; and (2) because Defendant committed two separate acts of interference, one inside his home and one outside his home, Defendant could lawfully be prosecuted for each separate offense. View "Redding v. State" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault and battery. Defendant appealed, arguing that the prosecutor committed prosecutorial misconduct by incorrectly instructing the jury regarding the presumption of innocence and by attempting to define “reasonable doubt” to the jury in his closing argument. The Supreme Court affirmed, holding (1) the prosecutor violated a clear and unequivocal rule of law when he made an incorrect statement regarding the presumption of innocence; (2) the prosecutor transgressed a clear and unequivocal rule of law when he defined reasonable doubt for the jury in his closing argument; but (3) while Defendant established that the prosecutor committed two errors that transgressed clear and unequivocal rules of law, the cumulative effect of these errors was not prejudicial. View "Watts v. State" on Justia Law

Defendant was charged with felony interference with a peace officer. Ultimately, the case was submitted to the jury. The jury deliberated for approximately four hours before it informed the district court that it was deadlocked. After discussion with counsel, the district court gave the jury a supplemental instruction asking the jurors to continue their deliberations. Less than one hour later, the jury returned a guilty verdict. Defendant appealed, arguing that the court’s supplemental instruction improperly coerced the jury and that his attorney provided ineffective assistance by failing to object to the instruction. The Supreme Court affirmed, holding (1) the supplemental instruction was not unduly coercive; and (2) defense counsel’s failure to object to the jury instruction did not constitute deficient performance. View "Carter v. State" on Justia Law

Defendant pleaded guilty to manslaughter and aggravated burglary. Defendant was sentenced to twelve to eighteen years for the manslaughter conviction and eight to ten years for the aggravated battery, to run concurrently, with a recommendation for the Youthful Offender Program (boot camp). After Defendant completed boot camp he moved for a sentence reduction to probation. The district court denied the motion but reduced Defendant’s sentence by two years. The Supreme Court affirmed, holding (1) following the successful completion of boot camp the sentencing court has discretion to reduce the sentence of an applicant upon completion of boot camp, and that discretion allows a reduction in sentence that could include probation but could also include other possibilities; (2) the district court did not abuse its discretion when it considered the nature of Defendant’s underlying crimes in Defendant’s motion for sentence reduction; and (3) the prosecutor did not violate the terms of the plea agreement when he argued against probation after completion of boot camp. View "Mendoza v. State" on Justia Law

In 2013, Appellant was convicted of ten felonies for acts perpetrated against his ex-girlfriend, their son, and Appellant’s six-year-old second cousin. The Supreme Court affirmed. In 2015, Appellant filed a motion for a new trial based on a recantation by his ex-girlfriend. The district court denied the motion. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Appellant’s motion for a new trial where the court found that the ex-girlfriend’s post-trial recantation was not credible and the court’s assessment that the ex-girlfriend’s “recantation of her recantation” constituted cumulative evidence relating to her credibility. View "Lindstrom v. State" on Justia Law