Justia Wyoming Supreme Court Opinion Summaries

Pursuant to a plea agreement, Defendant pled guilty to one count of first-degree sexual abuse of a minor. Defendant later filed a motion for sentence modification or reduction under newly discovered evidence arguing that his guilty plea was involuntary and that his trial counsel provided ineffective assistance. The district court construed the motion as both a motion to withdraw Defendant’s guilty plea and to reduce Defendant’s sentence. The district court denied the request to withdraw Defendant’s guilty plea, concluding that Defendant failed to establish newly discovered evidence resulting in manifest injustice, and concluded that it did not have jurisdiction to consider a sentence reduction because Defendant’s motion was untimely. Defendant appealed. The Supreme Court dismissed the appeal, holding that the district court did not have jurisdiction to rule on Defendant’s motion, and therefore, this Court did not have jurisdiction to consider Defendant’s appeal. View "Shue v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder and one count of attempted first degree murder. The jury trial began 210 days after Defendant’s arrest and 869 days after his arraignment. The district court sentenced Defendant to three consecutive sentences of life without the possibility of parole. The Supreme Court affirmed, holding (1) there was no violation of Defendant’s right to a speedy trial under Wyo. R. Crim. P. 48 and the Wyoming and United States Constitutions; (2) Defendant was not denied the effective assistance of counsel by his first appointed counsel; and (3) the district court did not abuse its discretion when it denied Defendant’s challenges for cause against two jurors. View "Castellanos v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of second degree sexual abuse of a minor. Defendant appealed, arguing that the district court erred by refusing his proffered instruction defining the term “inflicts” as used in the charged statute and that the district court erred by refusing to give a definition after the jury requested a dictionary. The Supreme Court affirmed, holding that the district court did not err in refusing Defendant’s proposed instruction or in failing to provide the jury with Defendant’s proffered definition of the term “inflicts” in response to the jury’s request for a dictionary. View "Marfil v. State" on Justia Law

Appellant pled guilty to escape and received a sentence that was suspended in favor of probation. Appellant’s probation was later revoked and the prison sentence for his escape conviction was re-imposed. Appellant subsequently pled guilty of failing to register and sentenced to a term of confinement. Appellant appealed, arguing that the district court erred by failing to consider his request for credit for time spent in presentence confinement. The Supreme Court affirmed, holding that the district court erred in concluding that it lacked the requisite authority to award credit for time served in presentence confinement. Remanded. View "Askin v. State" on Justia Law

Defendant was convicted of two counts of first-degree sexual assault and one count of kidnapping. The Supreme Court affirmed, holding (1) the district court did not commit plain error by failing to instruct the jury on the “incidental rule,” i.e., that confinement would not support a kidnapping conviction unless it was separate from and not merely an incident of the sexual assaults; and (2) there was no plain error in the district court’s reply to a question from the jury that the jurors should review the instructions already given by the court. View "Vaught v. State" on Justia Law

Appellant filed a 42 U.S.C. 1983 civil rights action in the district court asserting four federal constitutional claims and one state law claim, alleging that, while he was an inmate in the state of Wyoming under the supervision and control of the Wyoming Department of Corrections (DOC), he was deprived of his personal property, which violated his right to due process and caused him injury. The district court granted summary judgment on all claims for the DOC. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of the DOC. View "Chapman v. Wyo. Dep’t of Corr." on Justia Law

After a jury trial, Appellant was convicted of second-degree murder. The Supreme Court affirmed the conviction, holding that the district court did not err or abuse its discretion in (1) excluding evidence relating to the victim’s criminal history; (2) excluding Appellant’s proposed expert testimony regarding the character traits of persons who view depictions of child pornography; (3) declining Appellant’s request to instruct the jury regarding self-defense in a home or habitation; (4) instructing the jury, in relation to Appellant’s claim of self-defense, that it must determine whether Appellant or the victim was the first aggressor in this case; and (5) permitting the State to introduce Wyo. R. Evid. 404(b) evidence despite the State’s late notice of its intent to use the evidence. View "Knospler v. State" on Justia Law

After a jury trial, Appellant was convicted of aggravated assault and battery, simple assault, and strangulation of a household member. The Supreme Court affirmed Appellant’s conviction and sentence for aggravated assault and battery but reversed Appellant’s assault conviction and remanded for an order vacating that conviction and sentence, holding that the district court (1) did not commit plain error in instructing the jury on the elements of aggravated assault and battery under Wyo. Stat. Ann. 6-2-502(a)(i); but (2) erred in instructing the jury to consider assault as a lesser included offense of aggravated assault and battery under Wyo. Stat. Ann. 6-2-502(a)(iii), and the instruction was necessarily prejudicial to Appellant. View "Cecil v. State" on Justia Law

Pursuant to a plea agreement, Defendant pleaded no contest to one count of first degree sexual abuse of a minor and one count of second degree sexual abuse of a minor, both felonies. Defendant appealed, arguing that his convictions were invalid because the district court did not properly advise him that his future employment opportunities could be affected by loss of the privilege to possess firearms, as required by Wyo. Stat. Ann. 7-11-507. The Supreme Court affirmed, holding (1) Defendant waived his right to appeal the sufficiency of the firearms advisement in his plea agreement; and (2) the district court’s firearms advisement in this case was sufficient to satisfy the requirements of section 7-11-507. View "Henry v. State" on Justia Law

After a jury trial, Defendant was convicted of larceny. The district court revoked Defendant’s probation from a previous case and imposed the remainder of Defendant’s sentence. Defendant appealed in both cases. The Supreme Court affirmed both the probation revocation and the judgment and sentence on the larceny conviction, holding (1) the district court properly revoked Defendant’s probation from the previous case while the larceny case was still pending on appeal; and (2) the district court did not err in the larceny case by providing the jury with an instruction that stated the possession of recently stolen property, when supported by slight corroborative evidence, may support the inference that the possessor participated in the theft; and (3) there was sufficient evidence to convict Defendant of larceny. View "Pena v. State" on Justia Law