Justia Wyoming Supreme Court Opinion Summaries

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

Appellant was convicted of kidnapping and felony stalking. The Supreme Court reversed the stalking conviction but affirmed the kidnapping conviction. On remand, the district court amended the sentencing order. Appellant subsequently filed a motion and a second motion to correct an illegal sentence, arguing that the amended sentence improperly increased his punishment for kidnapping, that the public defender who represented him at trial improperly approved the amended sentence, and that the jury had been improperly instructed at trial. The district court denied the motions. The Supreme Court affirmed the denial of Appellant’s motions, holding that Appellant failed to establish that his amended kidnapping sentence was illegal. View "Hawes v. Wyoming" on Justia Law

After a jury trial, Defendant was found guilty of five counts of reckless endangering, three counts of aggravated assault, and one count of eluding police. The Supreme Court affirmed, holding (1) there was sufficient evidence presented at trial to convict Defendant of aggravated assault; (2) the district court erred in admitting evidence of law enforcement officers’ subjective reactions to a fired shot, but the error was not prejudicial; (3) the district court did not abuse its discretion when it denied Defendant’s motion for mistrial based upon prosecutorial misconduct; and (4) the prosecutor’s comments during closing argument did not constitute plain error. View "Hill v. State" on Justia Law

Appellant pled guilty to felony shoplifting and was placed on supervised probation for four years. Three years later, the State filed a petition to revoke Appellant’s probation, alleging that she violated the conditions of her probation on two separate occasions. Appellant admitted to the allegations of the petition and was subsequently sentenced to not less than four nor more than six years’ incarceration. Thereafter, Appellant filed a motion for sentence reduction, arguing that her good behavior and rehabilitative progress while incarcerated warranted a reduction. The district court denied the motion. The Supreme Court affirmed, holding (1) Appellant’s productive behavior alone did not require the district court to grant her a sentence reduction; and (2) the district court did not abuse its discretion in denying Appellant’s motion without describing information Appellant provided in support of her request for a reduction. View "Hart v. State" on Justia Law

After a jury trial, Defendant was convicted of misdemeanor unlawful possession of a controlled substance. Because it was Defendant’s third or subsequent offense, he was sentenced to three and a half years in prison with 228 days of credit for time served. Defendant appealed, arguing that there was insufficient evidence to convict him because the State failed to meet its burden to show the form of the substance he was charged with possessing. The Supreme Court affirmed Defendant’s conviction and sentence, holding (1) the pertinent statute does not require that the State prove, as an essential element, the form that was possessed by a defendant; and (2) the State met its burden when it proved that Defendant “knowingly or intentionally possessed a controlled substance[.]” View "Daley v. State" on Justia Law

Appellant was convicted of felony first-degree murder and sentenced to life without the possibility of parole. Appellant was nineteen years old at the time the murder was committed. Appellant filed a motion seeking a reduction of his sentence of life without the possibility of parole to life as a matter of law. The district court denied Appellant’s motion for sentence reduction. Appellant appealed, arguing that his life sentence without the possibility of parole violates the Eighth Amendment prohibition against cruel and unusual punishment and the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court affirmed on the grounds that Appellant did not raise the constitutional issues below, the equal protection argument was not cogently presented on appeal, and the Eighth Amendment claim was not of a fundamental nature. View "Poitra v. State" on Justia Law

Defendant entered into a plea agreement pursuant to which Defendant agreed to plead guilty to third degree sexual assault in exchange for a deferred prosecution and a five-year supervised probation. After Defendant had served nearly four years of probation, the district court modified the terms of her probation to require that she submit to and pay for a psycho-sexual evaluation. Defendant appealed, arguing that the district court improperly modified the conditions of her probation where there was no showing of a change in circumstances and no evidence presented to establish the need for the psychosexual evaluation in this case. The Supreme Court affirmed, holding (1) a sentencing court is not specifically required to find a change in circumstances before entering a modification order; and (2) under the circumstances of this case, the district court’s modification was not an abuse of discretion. View "Harada v. State" on Justia Law

After a jury trial, Defendant was found guilty of four counts of first degree sexual abuse involving two minors. Defendant was sentenced to life in prison without the possibility of parole. The Supreme Court affirmed, holding (1) the district court did not err by (i) rejecting Defendant’s ineffective assistance of counsel claim, (ii) determining that the child witnesses were competent to testify, (iii) denying Defendant’s requests for continuances, and (iv) admitting other bad acts evidence under Wyo. R. Evid. 404(b); (2) the district court erred in allowing the admission of some hearsay testimony at trial, but the errors were harmless; and (3) Defendant’s constitutional right to a speedy trial was not violated. View "Griggs v. State" on Justia Law