Justia Wyoming Supreme Court Opinion Summaries

Defendant entered a conditional plea to a fourth offense felony DWUI charge, reserving the right to challenge the denial of his motion to dismiss. The court found Defendant guilty of his fourth DWUI offense in a ten-year period and sentenced him to two to four years, suspended in favor of supervised probation. Defendant appealed, arguing that his 2005 conviction could not be used as a prior offense because it did not occur within ten years of his present conditional guilty plea. The Supreme Court affirmed, holding that the ten-year look-back period for enhanced DWUI penalties applies from the date of the last offense, rather than the date of the last conviction. View "Ramirez v. State" on Justia Law

Appellant was charged with felony possession of methamphetamine and misdemeanor interference with a peace officer. Appellant’s appointed counsel moved to suspend proceedings pending a competency evaluation. The trial court granted the motion. After a competency evaluation and competency hearing, the court found Appellant competent, and the matter proceeded to trial. The jury found Appellant guilty of interference with a peace officer, but a mistrial was declared on the possession charge. Thereafter, defense counsel suggested that a second competency evaluation was needed. The court ultimately concluded that a second competency evaluation was not warranted. Appellant then entered an Alford plea to felony possession of methamphetamine. Appellant appealed from both convictions. The Supreme Court affirmed, holding that any alleged error in the district court’s failure to suspend proceedings and order a second competency evaluation was inconsequential. View "Marshall v. State" on Justia Law

After a jury trial, Appellant was convicted of conspiracy to deliver a controlled substance. The district court sentenced Appellant to not less than four years nor more than eight years in prison. Appellant appealed, claiming that he received ineffective assistance of counsel because “a skilled criminal defense advocate would likely be able to secure a more favorable agreement than was obtained in his current sentence.” The Supreme Court affirmed, holding that Appellant failed to establish that he was prejudiced by counsel’s alleged deficient performance, and therefore, it was unnecessary to address the deficiency prong of the ineffectiveness standard. View "McNaughton v. State" on Justia Law

After a jury trial, Defendant was convicted of attempted second-degree murder and aggravated assault and battery. The district court sentenced Defendant to forty to fifty years in prison for the attempted murder and to a term of fifteen to fifty years for the aggravated assault and battery. Defendant appealed, challenging his sentences. The Supreme Court affirmed, holding (1) the cumulative sentences Defendant received upon conviction of the offenses of attempted second-degree murder and aggravated assault and battery did not offend principles of double jeopardy; and (2) the statutes under which Defendant was convicted were not unconstitutionally vague, either on their face or as applied to the facts of Defendant’s case. View "Jones v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of sexual abuse of a minor in the first degree. Defendant was sentenced to serve concurrent terms of fifteen to thirty-five years in prison. Defendant appealed, asserting that the prosecutor invaded the province of the jury by telling the jurors how to deliberate in violation of his right to a fair trial. The Supreme Court affirmed, holding (1) Defendant’s claim that the prosecutor improperly told the jury what to think was without merit; and (2) thus, Defendant failed to establish prosecutorial misconduct, and the district court did not err in overruling Defendant's objection to the prosecutor’s rebuttal argument. View "Watkins v. State" on Justia Law

After a jury trial, Defendant was found guilty of conspiracy to commit first-degree murder. Defendant was sentenced to life imprisonment. The Supreme Court affirmed, holding (1) the trial court erred when it allowed the State to play a video of an explosion of a “pipe bomb” because that video was not timely provided to defense counsel, but the error was not prejudicial; (2) the trial court abused its discretion when it allowed the State to use evidence - a bank statement - that the State did not timely provide to defense counsel, but the error was harmless; and (3) the trial court did not err in admitting character evidence under Wyo. R. Evid. 404(b) and in refusing to give a limiting instruction with regard to use of Rule 404(b) evidence. View "Brown v. State" on Justia Law

After a four-day jury trial, Defendant was found guilty of multiple counts of first degree sexual assault, battery, and unlawful contact without bodily injury. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress statements he made to a nurse during a sexual assault examination in an alleged violation of Defendant’s rights under Miranda v. Arizona; and (2) Defendant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48(b) and the Sixth Amendment to the United States Constitution. View "Tate v. State" on Justia Law

Defendant was sentenced to two life sentences according to law for crimes he committed in the 1990s. In 2015, Defendant filed a complaint against the Wyoming Board of Parole and the Wyoming Department of Corrections pursuant to the Declaratory Judgment Act, alleging various constitutional violations. The district court dismissed Defendant’s claims. The Supreme Court affirmed, holding (1) Wyo. Stat. Ann. 7-16-2016(a)(i) does not violate Defendant’s equal protection rights because there is a legitimate state interest in treating prisoners differently with respect to the statute; (2) the Wyoming Department of Corrections’ good time policy does not violate Defendant’s equal protection rights because prisoners serving life according to law and prisoners serving a term of years sentence are not similarly situated; (3) the enactment of section 7-16-205(a)(i) did not impliedly repeal Wyo. Stat. Ann. 7-13-402(a); (4) the Wyoming Board of Parole did not violate the doctrine of separation of powers by enacting policies governing the commutation application procedure; (5) Defendant’s due process rights were not violated by the amendment to the commutation application procedure; and (6) the Wyoming Board of Parole’s amendment to the commutation application procedure did not violate Defendant’s constitutional protection against ex post facto laws. View "Bird v. Wyoming Board of Parole" on Justia Law

After a jury trial, Appellant was found guilty of stalking. The district court sentenced Appellant to a term of three to five years in prison. Appellant appealed, arguing that the district court abused its discretion by not granting a mistrial for a violation of an order in limine concerning Wyo. R. Evid. 404(b) evidence and by imposing a discovery sanction that precluded the State from introducing untimely disclosed text messages but allowing the jury to hear testimony about them. The Supreme Court affirmed, holding that the district court did not err in not granting a mistrial and in not imposing a stiffer sanction for the discovery violation. View "Salinas v. State" on Justia Law

After a jury trial, Defendant was convicted of first degree arson for setting a fire in a Walmart store. Defendant was sentenced to a term of ten to eighteen years in prison. Defendant appealed, arguing that there was insufficient evidence to support his conviction because he was intoxicated at the time he set the fire. Therefore, Defendant argued, he should have only been charged with third degree arson. The Supreme Court affirmed Defendant’s conviction and sentence, holding that the State proved that, despite Defendant’s intoxication, Defendant acted maliciously with intent to destroy or damage an occupied structure, and therefore, there was sufficient evidence to support the conviction. View "Harnden v. State" on Justia Law