Justia Wyoming Supreme Court Opinion Summaries

Defendant pleaded guilty to larceny by bailee and two counts of false statement to obtain title. Defendant appealed, arguing (1) the district court erred in denying his motion to amend judgment and sentence in the larceny charge; (2) the district court erred in denying his motions to amend the captions in both criminal matters; and (3) with regard to his larceny by bailee charge, he was sentenced under a criminal statute that was repealed during the pendency of his proceedings. The Supreme Court dismissed the appeal for lack of jurisdiction because Defendant failed to timely file a direct appeal to the Court. View "Manzanares v. State" on Justia Law

After a jury trial, Appellant was convicted of felony possession of marijuana. The Supreme Court reversed the conviction for felony possession, holding (1) the evidence was insufficient to support Appellant’s conviction because, assuming a jury could reasonably find that Defendant could have controlled the marijuana, the State failed to show that Defendant had the intent and power to exercise dominion and control over the drugs; but (2) the evidence was sufficient to support the lesser included offense of misdemeanor possession of marijuana. Remanded for resentencing on that offense. View "Regan v. State" on Justia Law

After a jury trial, Appellant was convicted of child abuse and third-degree sexual assault of a minor under Wyo. Stat. Ann. 6-2-503(b)(i) and Wyo. Stat. Ann. 6-2-316(a)(iv). The Supreme Court affirmed, holding (1) Appellant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48 and under the Sixth Amendment to the United States Constitution; (2) the State presented sufficient evidence to sustain Appellant’s conviction of sexual abuse of a minor in the third degree; and (3) Appellant was not deprived of the effective assistance of trial counsel. View "Rhodes v. State" on Justia Law

Appellant pled guilty to one count of burglary and was placed on probation. As part of his probation, Appellant was required to complete a community corrections program and a residential treatment program. Appellant was confined in such a facility for a total of 187 days. After Appellant’s probation was revoked, the district court imposed the underlying sentence, but Appellant was not credited for the time he spent in the community corrections facility. Appellant later field a motion to correct illegal sentence seeking credit for the 187 days he spent in the community corrections facility. The district court ruled that Appellant was not entitled to credit for time spent in the community corrections facility. The Supreme Court reversed, holding that Appellant was entitled to 187 days of credit for time served in the community corrections facility. View "Nunes v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree sexual assault and two counts of third-degree sexual abuse of a minor. Defendant was sentenced as a habitual criminal to life imprisonment on the first-degree sexual assault conviction and two thirteen- and fifteen-years on the remaining two charges, to be served concurrently to each other and to the life sentence. The Supreme Court affirmed, holding (1) Defendant was serving in a position of authority over the victim; (2) Defendant was correctly charged; (3) the district court did not violate any rule of law by not merging Defendant’s convictions and sentences; and (4) Defendant was properly sentenced as a habitual criminal. View "Rogers v. State" on Justia Law

After a jury trial, Defendant was convicted of sexual abuse of a minor in the second degree. Defendant appealed, asserting that his trial attorney committed a number of errors during the course of the proceedings below, resulting in a violation of his constitutional right to the effective assistance of counsel. The Supreme Court affirmed the judgment and sentence of the district court, holding that Defendant failed to satisfy his burden of demonstrating that he suffered prejudice as a result of his trial counsel’s performance at trial, and therefore, Defendant’s ineffective assistance of counsel claim necessarily failed. View "Galbreath v. State" on Justia Law

Pursuant to a plea agreement, Defendant entered an Alford plea to aggravated assault and battery and to being a habitual offender. The district court sentenced Defendant to twelve to sixteen years of incarceration. Defendant later filed a pro se motion to correct an illegal sentence challenging his sentence enhancement pursuant to the habitual criminal statute. Specifically, Defendant argued that the habitual criminal statute is designed for those who demonstrate a pattern of violent conduct and that the State did not prove a pattern of violent conduct in his case. The district court denied the motion. The Supreme Court affirmed, holding that Defendant’s conduct fell directly within the habitual offender statute, and therefore, the district court properly enhanced his sentence within the enhanced penalty range. View "Harris v. State" on Justia Law

After a jury trial, Defendant was convicted of manslaughter and battery of a household member. Defendant appealed his manslaughter conviction. The Supreme Court affirmed, holding that the trial court did not err in (1) denying Defendant’s post-trial motion for judgment of acquittal in relation to the manslaughter conviction; (2) denying Defendant’s motion for a new trial based upon inadmissible hearsay, as the district court immediately intervened and then gave the jury a curative instruction; (3) refusing to instruct the jury on Defendant’s claim of self-defense; and (4) admitting into evidence the deceased victim’s 911 call. View "Bruce v. State" on Justia Law

Defendant pleaded guilty to one count of welfare fraud. Consistent with the plea agreement, the district court imposed a three to eight year sentence and ordered that Defendant pay $90,723 in restitution. Defendant appealed, arguing that it was not reasonable for the district court to order her to pay the entire restitution amount when it was clear from the record that she would be unable to pay it. The Supreme Court affirmed the district court’s restitution order, holding that, under the circumstances, the district court’s failure to find that Defendant had no ability to pay was not unreasonable, and its failure to find that no reasonable probability existed that she would have the ability to pay in the future was not unreasonable. View "Shafer v. State" on Justia Law

Pursuant to a plea agreement, Appellant pled guilty of charges of conspiracy to deliver methamphetamine and endangering a child. As part of the plea agreement, Appellant agreed to cooperate with the State in providing information to assist the State in its investigation of other criminal activity. Appellant agreed that, if he did not meet this obligation, he would not object to the State’s motion under Wyo. R. Crim. P. 35(a) for an increase in his sentence. Several months after Appellant was sentenced, the State moved to modify his sentence, asserting that Appellant had breached the plea agreement by failing to cooperate. The district court granted the motion and imposed a new, more severe sentence. The Supreme Court vacated Appellant’s sentence, holding that, despite the parties’ plea agreement, the district court lacked jurisdiction to increase the sentence because Rule 35 does not give the trial court jurisdiction to increase a previously-imposed, legal sentence. Remanded. View "Hamilton v. State" on Justia Law