Justia Wyoming Supreme Court Opinion Summaries

After Defendant was placed on probation, the State filed a petition to revoke his probation on the grounds that Defendant violated the conditions of his probation. The district court determined that Robinson had violated the terms of his probation because he failed to prove that he maintained employment and repeatedly failed to submit to a polygraph. Defendant appealed, arguing that the district court erred in both the adjudicatory and dispositional phases of the probation revocation process. The Supreme Court affirmed the revocation and imposition of Defendant’s sentences, holding that the district court did not err either in the adjudicatory or the dispositional phases of the probation revocation process. View "Robinson v. State" on Justia Law

After a jury trial, Defendant was convicted of seven counts of felony forgery and one count of misdemeanor theft. Defendant appealed, alleging that her prosecution was motivated by prosecutorial vindictiveness, that she received ineffective assistance of counsel, that the prosecutor argued facts not in evidence during closing arguments, that the district court erred by failing to provide supplemental instructions to the jury, and that the evidence was insufficient to support the convictions. The Supreme Court affirmed, holding (1) there was no plain error in Defendant’s claim of vindictive prosecution, in Defendant’s claim of prosecutorial misconduct, or in the district court’s refusal to provide supplemental instructions to the jury; (2) Defendant’s right to effective assistance of counsel was not violated; and (3) Defendant’s convictions were supported by sufficient evidence. View "Mraz v. State" on Justia Law

Appellant, an inmate at Wyoming’s medium-security correctional facility in Torrington, wrote a letter to the warden asking to inspect certain public records of that institution. The institution’s employees provided him with some, but not all, of the requested documents. Appellant subsequently filed a complaint for order of enforcement and request to show cause, asserting that because the institution’s employees had not timely completed their efforts to fulfill his records requests they effectively refused to comply under the law. The institution subsequently made available to Appellant the remainder of the requested records. Thereafter, the district court dismissed Appellant’s complaint. The Supreme Court affirmed, holding that the district court (1) properly confined the scope of its review to that permitted by the Wyoming Public Records Act, (2) properly found that Appellees fully complied with Appellant’s records request, and (3) properly received information regarding the warden’s initial response to that request. Further, there was no preemption of the WPRA. View "Guy v. Lampert" on Justia Law

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