Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court convicting Defendant, following a jury trial, of two counts of second-degree sexual abuse of a minor, holding that the prosecutor did not commit prosecutorial misconduct in the underlying proceedings.On appeal, Defendant argued that the prosecutor committed misconduct in the way he referred to and used the testimony of a forensic interviewer in his opening statement and closing argument. The Supreme Court disagreed and affirmed, holding (1) Defendant failed to establish that the prosecutor's statement violated a clear and unequivocal rule of law; and (2) there was no plain error in the State's closing argument. View "State v. Ward" on Justia Law

The Supreme Court answered a certified question by concluding that Wyo. Stat. Ann. 7-11-303 expressly grants circuit courts jurisdiction to address the competency of a person charged with a felony and suspend preliminary hearings before the person is bound over to the district court.Defendant was charged with two felonies. Before the preliminary hearing, defense counsel moved for a competency evaluation under section 7-11-303. The circuit court granted the motion and, after an evaluation, found Defendant fit to proceed. Thereafter, a preliminary hearing was held, and the matter was bound over to the district court. While the competency evaluation was pending the prosecutor filed an action seeking a writ of mandamus to compel the circuit court to hold a preliminary hearing. The circuit court certified the matter to the Supreme Court. The Supreme Court answered that the plain language of section 7-11-303(a) confers jurisdiction to circuit courts to address the competency of a person charged with a felony before they are bound over to the district court. View "Skoric v. Park County Circuit Court" on Justia Law

The Supreme Court affirmed the judgments of the district courts denying Appellants' separate motions to suppress, holding that the Wyoming Constitution does not require that an exterior canine sniff of a vehicle be supported by probable cause.Appellants in these cases were both subjected to an extended investigative detention, and both Appellants were arrested after a canine sniff of their vehicles. On appeal, Appellants argued that the canine sniffs had to be supported by probable cause under Wyo. Const. art. I, 4. The Supreme Court disagreed, holding (1) the Wyoming Constitution does not require probable cause for an exterior canine sniff of a vehicle; and (2) Appellants were not entitled to relief on their remaining allegations of error. View "Tarzia v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction on one count each of stalking in violation of a protective order and criminal entry, holding that the prosecutor did not make improper comments in closing argument and that the district court did not plainly err in defining "spying distance."On appeal, Defendant argued that the prosecutor committed prosecutorial misconduct in closing by commenting on Defendant's silence and that the district court erred in allowing the State's witness to discuss "spying distance," a term not referenced in the stalking statute. The Supreme Court affirmed but remanded the case for correction of the date in the judgment and sentence, holding (1) Defendant failed to establish plain error as to his first two arguments on appeal; and (2) the district court did not plainly err when it allowed the State's witness to testify regarding his understanding of the definition of "spying distance." View "Hembree v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion for sentence reduction, holding that the district court did not abuse its discretion in denying the motion.Appellant pled guilty to aggravated assault and battery and was sentenced to a period of incarceration for not less than four years nor more than eight years. Appellant later filed a motion for a sentence reduction requesting that the district court reduce his sentence to not less than three years nor more than six years based on his commendable conduct while incarcerated. The district court denied the motion. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it denied Defendant's motion for sentence reduction. View "Harper v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's claims against Defendant, the mayor of Green River, as time-barred, barred under 42 U.S.C. 1983, and barred by the doctrine of collateral estoppel, holding that the district court did not err.In his complaint, Plaintiff alleged that Defendant violated his oath of office during Plaintiff's underlying criminal matter by declining to order an investigation into a witness who recanted prior statements she made to law enforcement. The district court dismissed the complaint. The Supreme Court affirmed, holding (1) the district court did not err when it determined that Plaintiff's claims were barred by the Wyoming Governmental Claims Act and 42 U.S.C. 1983; (2) Plaintiff failed to present cogent argument on his collateral estoppel argument; and (3) therefore, the district court properly granted Defendant's motion to dismiss. View "Mitchell v. Rust" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony possession of methamphetamine, holding that the district court did not err in denying Defendant's multiple motions to suppress challenging the validity of the warrant and supporting affidavit police obtained to search his residence.On appeal, Defendant argued that Officer Andy Lucas of the Gillette Police Department knowingly, or with reckless disregard, omitted facts from the search warrant affidavit and that the warrant was not sufficiently particular to remain valid under the Fourth Amendment. The Supreme Court disagreed, holding (1) the district court did not clearly err in finding Officer Lucas had not recklessly omitted information from the affidavit; and (2) the search warrant contained sufficient information to allow Officer Lucas to identify the place to be searched with reasonable effort. View "Herdt v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained after law enforcement forced open a lacked box during an inventory search of Defendant's vehicle, holding that the district court did not err.During an inventory search of Defendant's vehicle, the police forced open a locked box and discovered suspected illegal drugs. The State charged Defendant with felony possession of methamphetamine and misdemeanor possession of heroin. Defendant moved to suppress the evidence obtained from the box, arguing that opening the box exceeded the scope of a permissible inventory search in violation of the Wyoming Highway Patrol's (WHP) inventory policy, thus violating his Fourth Amendment rights. The district court denied the motion, after which Defendant entered a conditional plea of guilty to felony possession of methamphetamine. The Supreme Court affirmed, holding that Defendant's argument that the inventory search violated WHP policy was unavailing. View "Beckwith v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion for sentence reduction, holding that Defendant was not entitled to relief on his claim that the district court abused its discretion by relying upon the State's misrepresentation of Defendant's criminal history when denying his motion.Defendant pled guilty pursuant to a plea agreement to felony domestic battery and was sentenced to three to six years in prison. Defendant later filed a pro se motion for sentence reduction. The district court denied the motion. The Supreme Court affirmed, holding that where Defendant failed to show that the district court actually relied upon the State's misrepresentation of his criminal history when denying his motion for sentence reduction, the district court did not abuse its discretion by denying the motion. View "Bulisco v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of third-degree sexual abuse of a minor, holding that there was sufficient evidence to support the conviction.Defendant was convicted of sexually assaulting his niece, DT. On appeal, Defendant argued that DT's testimony during trial lacked credibility and could not support his conviction and that, alternatively, the State was only able to establish the first element of the offense through leading questions. The Supreme Court rejected Defendant's arguments and affirmed, holding that the evidence was sufficient to support the jury's verdict. View "Deephouse v. State" on Justia Law