Justia Wyoming Supreme Court Opinion Summaries

After a trial, Defendant was convicted of five counts of sexual abuse of a minor in the first degree. Defendant appealed, arguing that the district court committed plain error by admitting testimony about the presumption of paternity applicable to DNA evidence that showed Defendant impregnated his minor victim. The Supreme Court affirmed, holding (1) there was no plain error where the testimony in question was only relevant to support Wyo. R. Evid. 404(b) evidence rather than any elements of the charged office; and (2) Defendant’s due process rights were not violated where there was no indication that the State relied on this evidence to shift its burden of proof to Defendant. View "Snyder v. State" on Justia Law

After a jury trial, Defendant was found guilty of felony theft. The Supreme Court affirmed, holding (1) there was sufficient evidence for the jury to reasonably conclude that Defendant possessed the requisite intent to deprive; (2) the district court did not abuse its discretion when it imposed no sanction for the State’s discovery violation; (3) the district court erred when when it allowed evidence of Defendant’s prior felony conviction, but the error was harmless; (4) the district court did not commit plain error when it prohibited defense counsel from questioning a police officer about Defendant’s “nonstatements” made during his interview following his arrest; and (5) Defendant waived his right to challenge the district court’s response to the jury question under the invited error doctrine. View "Toth v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree sexual abuse of a minor and one count of second-degree sexual abuse of a minor. The Supreme Court affirmed, holding (1) the district court did not err in admitting evidence of Appellant’s prior conviction for sexual assault; (2) the district court did not err in excluding evidence of the victim’s prior sexual conduct; (3) the district court did not err in admitting evidence of domestic abuse; and (4) the prosecutor did not commit misconduct in his statements made during closing argument. View "Carroll v. State" on Justia Law

After a jury trial, Defendant was convicted of strangulation of a household member. Defendant appealed, arguing that the district court committed reversible error by failing to instruct the jury on the lesser included offenses of battery and domestic battery. Because of the dates the statutes in question went into effect, the question for the Supreme Court’s determination was whether the district court should have instructed the jury on the offense of battery. The Supreme Court affirmed, holding that the district court did not err in refusing Appellant’s lesser included offense instruction because there was no evidence to support it. View "Nickels v. State" on Justia Law

After a jury trial, Defendant was convicted of aiding and abetting aggravated robbery. Defendant appealed, arguing that the district court denied him the right to due process by declining to instruct the jury on his defense of duress. The Supreme Court reversed and remanded for a new trial, holding that Defendant was denied his right to a fair trial when the district court refused to instruct the jury on Defendant’s defense of duress after Defendant testified and admitted the elements of the crime. Given the evidence presented in this case, Defendant was entitled to a jury determination as to whether he had a reasonable opportunity to avoid the crime. View "James v. State" on Justia Law

Appellant pled guilty to second degree murder and was sentenced to serve seventy-five years to life in prison. On appeal, Appellant contended that the district court considered improper evidence in determining his sentence. Applying plain error review, the Supreme Court affirmed, holding (1) the district court did not err by considering during sentencing statements from individuals who did not meet the statutory definition of victim; and (2) the trial court did not err in allowing the State to present evidence at sentencing that Appellant claimed was in violation of Wyo. R. Crim. P. 32. View "Town v. State" on Justia Law

Defendant pleaded guilty to one count of second degree sexual abuse of a minor. The district court sentenced Defendant to five to ten years of incarceration but suspended the sentence and ordered him to serve six years on supervised probation. After Defendant was released on probation, the State petitioned to revoke Defendant’s probation, alleging several violations of the conditions of his probation. After a hearing, the district court revoked Defendant’s probation. The Supreme Court affirmed, holding that the district court (1) did not commit reversible error by failing to make an express finding that Defendant’s probation condition violations were willful; and (2) did not abuse its discretion by revoking Defendant’s probation. View "Miller v. State" on Justia Law

After a jury trial, Defendant was found guilty of three counts of delivery of cocaine. The Supreme Court reversed the conviction and remanded for a new trial, holding (1) the evidence was sufficient to support the conviction; (2) Defendant was not denied his right to confrontation when law enforcement officers testified about results of tests conducted by others; (3) the prosecutor did not commit misconduct; but (4) Defendant’s trial counsel rendered ineffective assistance by failing to object to improper testimony and argument, by failing to demand notice of Wyo. R. Crim. P. 404(b) evidence and enter an objection to the testimony, and by failing to request that audio tapes of controlled buys be played in their entirety, and Defendant was prejudiced by counsel’s deficient performance. View "Fennell v. State" on Justia Law

After a jury trial, Appellant was convicted of second-degree murder. On appeal, Appellant argued that the jury was not properly instructed on the element of malice under the Court’s decision in Wilkerson v. State, which was issued after Appellant’s conviction. The Supreme Court affirmed, holding that because Appellant failed to show a reasonable probability that he would have received a more favorable verdict had the jury been instructed in accordance with Wilkerson, Appellant did not show that the instructional error resulted in material prejudice to him, and therefore, there was no plain error in the jury instructions. View "Miller v. State" on Justia Law

Defendant entered a conditional plea to possession of marijuana with intent to deliver and possession of methamphetamine with intent to deliver. Defendant was sentenced to two consecutive sentences of seven to ten years and fourteen to eighteen years. The Supreme Court affirmed. After unsuccessfully seeking a sentence reduction, postconviction relief, and habeas relief, Defendant filed a motion to correct an illegal sentence, arguing that his sentences violated double jeopardy. The district court denied the motion on the basis of res judicata. The Supreme Court affirmed, holding that Defendant’s claims were barred by res judicata. View "Tucker v. State" on Justia Law