Justia Wyoming Supreme Court Opinion Summaries

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

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

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

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

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

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