Justia Wyoming Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of one count of felony interference with a peace officer and of operating an ATV without liability insurance or valid registration. Defendant appealed, challenging her felony interference conviction. The Supreme Court affirmed, holding that the district court did not err in (1) denying Defendant’s motion for judgment of acquittal because the evidence was sufficient to support the conviction; (2) failing to give the jury Defendant’s proffered self-defense instructions; and (3) failing to provide the jury with definitions of phrases contained in the felony interference charge. View "Mceuen v. State" on Justia Law

After a jury trial, Defendant was convicted of first degree murder. Defendant appealed, raising four issues related to his position at trial that the killing was not premeditated murder but, rather, the lesser included offense of voluntary manslaughter. The Supreme Court reversed due to structural error, holding that the jury instructions created reversible error as to the lesser included offense of voluntary manslaughter because they instructed the jury that the State had to prove beyond a reasonable doubt that Defendant acted in a sudden heat of passion, when the burden should have been to disprove that factor. Remanded for a new trial of the first degree murder charge. View "Shull v. State" on Justia Law

Defendant entered a conditional no contest plea to possession of methamphetamine with the intent to distribute. Defendant appealed, arguing that the district court erred in denying his motion to suppress and finding that Defendant consented to continued detention when law enforcement told him “he was free to leave” but continued to have [its] red and blue emergency overhead lights activated. The Supreme Court affirmed, holding that, under the totality of the circumstances in this case, a reasonable person in Defendant’s position would have felt free to decline the law enforcement officer’s request, and therefore, the contact between the officer and Defendant was consensual. View "Tibbetts v. State" on Justia Law

Appellant Bruce Williams asked the Circuit Court for a copy of part of a presentence investigation report in a criminal case. The circuit court denied his request. He brought a petition for a writ of mandamus asking the district court to require that the circuit court release the records. The district court dismissed the case. He appealed, claiming a constitutional right as a member of the public to access these records. Because he did not present his constitutional arguments to the district court, the Supreme Court affirmed. View "Williams v. Tharp" on Justia Law

Defendant was convicted of four felony counts of obtaining property by false pretenses and one misdemeanor count of official misconduct. Defendant appealed, arguing that the State was required to prove that the title to the property at issue passed from Albany County to him and that the State failed to prove that it did. The Supreme Court (1) reversed the four felony convictions, holding that there was insufficient evidence to prove beyond a reasonable doubt that Defendant committed the crime of obtaining property by false pretenses, and (2) the Court declines to consider Defendant’s claim regarding the misdemeanor conviction of official misconduct because Defendant failed to provide cogent argument on this issue. View "Bohling v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of felony interference with a peace officer, one count of misdemeanor interference with a peace officer, and one count of misdemeanor simple assault. The Supreme Court affirmed, holding (1) the district court did not err in failing to give the jury Defendant’s proposed theory of defense instructions; and (2) Defendant’s Sixth Amendment right to effective assistance of counsel was not violated by trial counsel’s failure to file a motion to suppress, renew the motion for judgment of acquittal at the end of trial, and propose certain theory of defense instructions. View "Tingey v. State" on Justia Law

Defendant was convicted of felony possession of methamphetamine and possession of methamphetamine with intent to deliver. Defendant appealed his conviction on the charge of possession with intent to deliver, arguing that the district court erred when it admitted evidence of a prior drug transaction. Further, Defendant claimed that because felony possession is a lesser included offense of possession with intent to deliver, the district court erred in convicting and sentencing him on both counts. The Supreme Court reversed Defendant’s conviction for possession with intent to deliver, holding (1) the district court erroneously admitted the evidence of Defendant’s prior drug transaction; and (2) it is therefore unnecessary to consider Defendant’s second issue. View "Overson v. State" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree sexual assault and one count of battery of a household member. The Supreme Court affirmed, holding (1) trial counsel for Defendant did not provide ineffective assistance when he failed to challenge the credibility of the alleged victim; (2) Defendant failed to establish that the State committed a violation of Brady v. Maryland when the prosecutor allegedly failed to disclose exculpatory evidence relating to the alleged victim; and (3) the State presented sufficient evidence to support Defendant’s conviction for battery of a household member. View "Worley v. State" on Justia Law

After a one-day jury trial, Defendant was convicted of three counts of sexual abuse of a minor in the second degree. Defendant appealed, arguing that the district court abused its discretion when it admitted evidence that Defendant was in violation of his parole at the time of the offenses. The Supreme Court affirmed, holding that the district court did not abuse its discretion in admitting evidence relating to the terms of Defendant’s parole and his parole violations, as the district court considered the required Gleason criteria and had a legitimate basis for its conclusions. View "Vasquez v. State" on Justia Law

Defendant was charged with felony stalking. Defendant’s first jury trial ended in a mistrial. Thereafter, a second jury found Defendant guilty of felony stalking. Defendant was sentenced to a term of incarceration, suspended on the condition that Defendant complete five years of probation. Defendant appealed, arguing that his rights against double jeopardy were violated because the prosecutor forced him into moving for a mistrial. The Supreme Court affirmed, holding (1) there was no evidence in the record indicating prosecutorial intent to provoke the defense into moving for a mistrial; and (2) therefore, Defendant’s rights against double jeopardy were not violated in this case. View "Montoya v. State" on Justia Law