Justia Wyoming Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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After a jury trial, Appellant was convicted of larceny by bailee. The district court sentenced Appellant to eight to ten years in prison but suspended the sentence and placed him on probation. The court also ordered Appellant to pay restitution in the amount of $127,208. The Supreme Court affirmed, holding (1) because he failed to demonstrate prejudice by his counsel’s alleged errors, Appellant could not prevail on his claim that he was denied his right to effective assistance of counsel; and (2) the district court did not abuse its discretion in ordering Appellant to pay restitution in the amount of $127,208. View "Hibsman v. State" on Justia Law

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After a jury trial, Defendant was convicted of one count of second-degree sexual abuse of a minor. The district court sentencing Defendant to a period of seven to fifteen years incarceration. The Supreme Court affirmed, holding (1) there was sufficient evidence presented at trial to sustain the conviction; (2) the district court did not abuse its discretion when it denied Defendant probation and sentenced him instead to serve time in prison; and (3) the district court did not commit plain error by considering inappropriate factors in its sentencing decision. View "Butler v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was found guilty of attempted first degree murder, aggravated burglary, conspiracy to commit aggravated burglary, and aggravated assault. Defendant was sentenced to a term of life on the attempted first degree murder conviction. The Supreme Court affirmed the convictions, holding (1) the district court incorrectly instructed the jury on the definition of malice, but Defendant was not prejudiced by the improper instruction; and (2) the district court did not err in denying Defendant’s motion for judgment of acquittal on the conspiracy charge, as sufficient evidence was presented to sustain the conviction for conspiracy to commit aggravated burglary. View "Johnson v. State" on Justia Law

Posted in: Criminal Law
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Phillip Sam was charged as an adult with one count of first degree murder and twelve counts of aggravated assault. Sam was sixteen years old at the time of the offense, and several witnesses set to testify at trial were juveniles. After a hearing, the district court entered an order concerning media access during trial that limited the identification of juvenile witnesses who would testify during the trial in open court, concluding that this measure was necessary because some of the juvenile witnesses had been the subject of threats. Petitioner, a newspaper, challenged the prior restraint on publication imposed by the court. The Supreme Court reversed and vacated the district court’s order pertaining to the release of the names of juvenile witnesses, holding that the district court’s order violated the First Amendment because this was not the sort of exceptional case where the district court’s prior restraint on speech survives constitutional scrutiny. View "Cheyenne Newspapers, Inc. v. First Judicial Dist. Court" on Justia Law

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In 1994, Appellant pled guilty to kidnapping and and first-degree sexual assault while he was on parole for an unrelated crime. Appellant was sentenced to two concurrent terms of life imprisonment. In 2014, Appellant, acting pro se, filed a second motion to correct illegal sentence. The district court awarded Appellant thirty-seven days of credit for presentence confinement and denied the remainder of Appellant’s claims. The Supreme Court affirmed, holding that the district court did not err in denying Appellant’s motion to correct an illegal sentence under the circumstances of this case. View "Bird v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of two counts of first-degree sexual abuse of a minor for sexually assaulting his teenage daughter. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting certain uncharged misconduct at trial; (2) Defendant’s trial counsel did not provide ineffective assistance by not uncovering certain evidence in time to be used at trial; and (3) Defendant’s due process rights were not violated when his appeal was delayed due to the court reporter’s untimely filing of the transcripts from the proceedings below. View "Hodge v. State" on Justia Law

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Defendant pled guilty to third-degree sexual assault and nolo contedere to abuse of a vulnerable adult. Defendant appealed, arguing that neither plea was informed because the court failed adequately to explain the charges and establish sufficient factual bases. The Supreme Court affirmed, holding that the district court (1) adequately explained the nature of Defendant’s third-degree sexual assault charge and obtained a sufficient factual basis for his guilty plea; and (2) adequately explained the nature of Defendant’s abuse of a vulnerable adult charge, and furthermore, because the court accurately and completely recited the elements of the charge, no other factual basis was necessary prior to accepting the plea. View "Williams v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Appellant was convicted of voluntary manslaughter, a lesser included offense of first-degree murder. At trial, Appellant claimed he was acting in self-defense when he shot the victim. Appellant appealed, arguing that the district court erred in excluding evidence indicating that the victim was under the influence of methamphetamine at the time of the events leading to his death. Specifically, Appellant contended that the evidence was admissible because it was relevant to Appellant’s claim of self-defense. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it excluded any reference to methamphetamine use by the shooting victim, as the evidence was not relevant to Appellant’s self-defense claim. View "Lawrence v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted for aiding and abetting aggravated robbery. Defendant appealed, asserting that the district court denied him the right to due process when it refused to instruct the jury on his defense of duress. The Supreme Court reversed and remanded for a new trial, holding that the district court denied Defendant of his right to a fair trial when it ruled that the duress defense instruction would not be given to the jury after Defendant testified and admitted the elements of the crime, as the facts of the case were sufficient to establish a jury question as to Defendant’s duress defense. View "James v. State" on Justia Law

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After a jury trial, Defendant was found guilty of one count of second degree sexual abuse of a minor. Defendant appealed, arguing that prosecutorial misconduct occurred in four instances. The Supreme Court affirmed, holding (1) the prosecutor’s comments on defense counsel’s failure to produce certain evidence did not prejudice Defendant; (2) prosecutorial misconduct did not occur when the prosecutor commented on the fact that Defendant did not confess to the crime charged; and (3) the prosecutor did not elicit opinions concerning witness credibility or personally vouch for the credibility of a witness. View "Collins v. State" on Justia Law

Posted in: Criminal Law