Justia Wyoming Supreme Court Opinion Summaries

The three petitioners in this case (collectively, “Petitioners”) were held in the Fremont County Detention Center on unrelated criminal charges. None of the Petitioners were able to post the cash-only bail imposed by the lower courts as a condition of their pretrial release. As a result, each Petitioner remained in jail pending trial. Each Petitioner filed a petition to the Supreme Court for habeas corpus relief seeking immediate release from the detention center and requesting a determination that cash-only bail is impermissible under the Wyoming Constitution and Rules of Criminal Procedure. The Supreme Court consolidated the petitions for review and affirmed the lower courts’ use of cash-only bail, holding that cash-only bail does not violate Wyo. Const. art. I, 14 or Wyo. R. Crim. P. 46.1. View "Saunders v. Hornecker" on Justia Law

After a jury trial, Defendant was found guilty of fifteen counts of felony Medicaid fraud and one count of misdemeanor Medicaid fraud. Defendant appealed, arguing, among other things, that the State failed to present sufficient evidence that he provided “medical assistance” to Medicaid recipients as defined in the relevant statute. The Supreme Court affirmed in part and remanded in part, holding that the district court (1) did not abuse its discretion in denying Defendant’s motion for judgment of acquittal because the State produced sufficient evidence that Defendant provided “medical assistance”; (2) did not err in instructing the jury; but (3) erred in its sentence on one of the counts. Remanded for resentencing. View "Adekale v. State" on Justia Law

After a jury trial, Defendant was found guilty of three counts of first degree sexual abuse of a minor and three counts of second degree sexual abuse of a minor for acts involving two victims. Defendant was also found guilty of two counts of aggravated assault and two counts of first degree sexual assault for acts involving an adult victim. The Supreme Court affirmed the convictions, holding (1) the district court erred when it allowed the State to introduce un-noticed character evidence, but the error was harmless; (2) the State's amendment to the information did not prejudice Defendant’s substantial rights; and (3) Defendant was not denied his right to a fair trial due to prosecutorial misconduct. View "Lindstrom v. State" on Justia Law

Defendant was charged with escape from official detention. Defendant later filed a motion to dismiss the escape charge due to an alleged failure to bring him to trial within the time limits contained in Wyoming’s Interstate Agreement on Detainers (IAD) statute. The district court denied the motion to dismiss. Appellant subsequently entered a conditional guilty plea, reserving his right to appeal the denial of his motion to dismiss. The Supreme Court affirmed, holding that the speedy trial provisions of the IAD did not require that the charge against Defendant be dismissed because the IAD did not apply in this case. View "Turner v. State" on Justia Law

After a jury trial, Appellant was found guilty of second-degree murder for shooting and killing his cousin. Appellant was also found guilty of kidnapping-confinement and first-degree sexual assault relating to conduct involving his cousin’s girlfriend. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it instructed the jury that it could presume malice from the use of a deadly weapon; and (2) the district court did not err in denying Appellant’s motion to sever the second-degree murder charge from the other charges of kidnapping and sexual assault. View "Hereford v. State" on Justia Law

Appellant pleaded guilty to attempted second-degree murder. The district court accepted Appellant’s guilty plea and sentenced him to not less than twenty-five and no more than fifty years incarceration. After unsuccessfully moving to withdraw his guilty plea and filing a petition for post-conviction relief, Appellant filed a Wyo. R. Crim. P. 35(b) motion for sentence reduction, requesting that his sentence be reduced to fifteen to twenty-five years. The district court denied the motion. The Supreme Court affirmed, holding that Appellant failed to overcome his burden of proving that the district court abused its discretion in denying his Rule 35(b) motion. View "Chapman v. State" on Justia Law

Following Defendant’s involvement in an automobile accident, law enforcement officers searched Defendant’s vehicle and found marijuana. Defendant was subsequently charged with felony possession of marijuana. Defendant moved to suppress the evidence obtained in the search of his vehicle as well as his statements to law enforcement, arguing that the investigating officer impermissibly extended the scope of his detention. The district court denied the motion to suppress. Thereafter, Defendant pleaded guilty to the charge, reserving the right to appeal the court’s order denying his motion to suppress. On appeal, instead of challenging the search of his vehicle, Defendant argued that the State failed to present sufficient evidence at the suppression hearing concerning the certification of the drug dog used by the investigating officer to conduct a free-air sniff outside Defendant’s vehicle. The Supreme Court affirmed, holding that in entering his conditional plea, Defendant did not properly reserve any questions concerning the reliability of the drug dog, and therefore, that issue may not be addressed here. View "Ward v. State" on Justia Law

At approximately 10:18 p.m., police officers searched Defendant’s home pursuant to a search warrant and found marijuana and drug paraphernalia. Defendant was subsequently arrested and charged with delivery of and possession with intent to deliver a controlled substance. Defendant filed a motion to suppress the evidence seized in the search, arguing that the search was unlawful and in violation of his constitutional rights because the search warrant was served after 10 p.m. contrary to the plain language of the warrant. The district court granted the motion to suppress based upon a procedural violation of Wyo. R. Crim. P. 41(c). The Supreme Court reversed, holding that although the officers violated Rule 41(c), the violation did not warrant suppression of the evidence seized in the search under the circumstances of this case. View "State v. Deen" on Justia Law

After a jury trial, Appellant was convicted of one count of attempted second-degree sexual abuse of a minor. The Supreme Court affirmed, holding (1) the district court did not err by not declaring a mistrial after one potential juror made an improper remark and others who were ultimately excused became emotional during voir dire; (2) the district court did not abuse its discretion by supplementing the jury instructions consistent with the Information to clarify the conduct charged; and (3) the delay between Appellant’s conviction and sentencing did not violate his constitutional right to speedy sentencing. View "Brown v. State" on Justia Law

Defendant pleaded guilty to a third or subsequent offense of possession of a controlled substance, a felony, and misdemeanor driving while under the influence. The Supreme Court affirmed, holding that the district court did not err by ordering Defendant to receive and pay for a substance abuse assessment and then by relying on the assessment at sentencing to determine that defendant was a “qualified offender” and, in turn, recommending that Defendant successfully complete substance abuse treatment while in prison through the Intensive Treatment Unit or a comparable program, as the district court’s decision was in accordance with the law. View "Marshall v. State" on Justia Law