Justia Wyoming Supreme Court Opinion Summaries

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

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