Justia Wyoming Supreme Court Opinion Summaries

In 1997, Appellant pleaded guilty to one count of second degree murder. In 2013, Appellant filed a pro se “Motion for Withdrawal of Plea, and/or Correction/Reduction of an Illegal Sentence.” The district court granted in part and denied in part Appellant’s request to correct an illegal sentence. Specifically, the court concluded that a provision of Appellant’s sentence that required him to repay the costs of his presentence confinement in county jail was illegal and vacated it, but the court denied the remainder of Appellant’s claims. The Supreme Court affirmed, holding that the district court (1) correctly ruled that it did not have jurisdiction to address Appellant’s motion to withdraw his guilty plea even though it found an illegal assessment included in his original sentence; (2) properly ruled that it did not have jurisdiction to consider, in a motion to correct an illegal sentence, how Appellant’s sentence was being administered; and (3) properly ruled that it did not have jurisdiction to consider Appellant’s motion to reduce his sentence. View "Pfeil v. State" on Justia Law

After a jury trial, Appellant was convicted of second degree murder. On appeal, Appellant argued, among other things, that the district court erred in instructing the jury on the malicious intent element of second-degree murder. The Supreme Court reversed the conviction, holding (1) the jury instructions regarding the definition of malice as that term is used in Wyoming’s second-degree murder statute were in accord with Supreme Court precedent; but (2) the definition of malice contained in Court precedent does not satisfy the malicious intent requirement of second-degree murder, and therefore, this precedent must be overturned, and Appellant’s convictions must be reversed. View "Wilkerson v. State" on Justia Law

Appellant, an inmate serving a sentence of life imprisonment, filed a 42 U.S.C. 1983 civil rights action against Appellees, three employees of the Wyoming Department of Corrections, alleging that Appellees violated his federal constitutional right to due process by placing his earnings in a mandatory savings account from which he could not withdraw without a hearing. The district court dismissed the complaint. Appellant did not appeal the order dismissing his case but, instead, filed a motion for relief from the order of dismissal under Wyo. R. Civ. P. 60(b)(5) and (6). The district court denied the rule 60(b) motion. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the motion and that Appellant failed to show that his failure to receive Appellees’ response to his motion deprived him of due process. View "Nicodemus v. Lampert" on Justia Law

After a jury trial, Appellant was found guilty of stalking and kidnapping. The Supreme Court reversed the stalking conviction and otherwise affirmed, holding (1) there was insufficient evidence to support the stalking conviction; (2) the jury correctly found that Appellant was not entitled to a mitigated sentence for the kidnapping charge, as there was sufficient evidence for the jury to conclude that Appellant did not voluntarily release his kidnapping victim; and (3) the jury was properly instructed on the lesser included charge of felonious restraint, a lesser included offense to the crime of kidnapping. View "Hawes v. State" on Justia Law

After a jury trial, Appellant was convicted of four counts of sexual abuse of a minor in the second degree and was sentenced to thirteen to fifteen years on each count, to be served consecutively. The Supreme Court affirmed on appeal. Appellant subsequently filed a pro se motion for sentence reduction pursuant to Wyo. R. Crim. P. 35(b) requesting that the district court merge his sentences on the grounds that all of the charges stemmed from the same offense and therefore violated the prohibition against double jeopardy. The district court denied the motion. The Supreme Court affirmed, holding that Appellant’s claim was barred by res judicata because he failed to present his double jeopardy claim in his initial appeal. View "Leonard v. State" on Justia Law

Defendant was a juvenile when he was convicted in 1995 of felony murder and sentenced to life in prison, a sentence that was by operation of law the equivalent of life imprisonment without the possibility of parole. In 2013, Defendant filed a motion to correct an illegal sentence, arguing that his sentence of life without the possibility of parole was unconstitutional under Miller v. Alabama. The district court certified two questions to the Supreme Court regarding the retroactivity of Miller. The Supreme Court held (1) the proper rule for determining whether a new constitutional rule applies retroactively to cases on collateral review is the test announced by the U.S. Supreme Court in Teague v. Lane; (2) under a Teague analysis, the rule announced in Miller applies retroactively to cases on collateral review; and (3) by operation of the amended parole statutes, the current sentence Defendant was serving was life with the possibility of parole after twenty-five years of incarceration. View "State v. Mares" on Justia Law

In 2009, Defendant pleaded guilty to drug possession. The district court later revoked Defendant’s probation but reinstated it on the condition that Defendant complete an in-patient treatment program. The court stated that Defendant would earn credit against his sentence for time spent in substance abuse treatment. In 2013, Defendant again violated the terms of his probation. At a hearing, the district court imposed the underlying sentence. Defendant sought credit for the time he spent in treatment, but the district court refused to award him such credit, concluding that the Supreme Court’s jurisprudence prohibited the award. The Supreme Court reversed, holding that the district court had discretion to award Defendant credit for time he spent in in-patient treatment and should have done so, in accordance with its earlier ruling, if Defendant successfully completed treatment. Remanded for a determination of whether Defendant successfully completed treatment. View "Daniels v. State" on Justia Law

Defendant pleaded guilty to five counts of second-degree sexual abuse of a minor. The district court sentenced Defendant to terms of imprisonment and ordered that Defendant be given credit for 721 days of pre sentence confinement. The court, however, did not specify how those days should be applied to Defendant's sentence. Defendant appealed. The Supreme Court affirmed on all issues but remanded to the district court to specify how the credit for presentence confinement should be applied, holding (1) the prosecutor did not breach the plea agreement or engage in prosecutorial misconduct; and (2) the sentence’s reference to credit for presentence confinement was not sufficiently specific to comply with Wyo. R. Crim. P. 32(c)(2)(F). View "Deeds v. State" on Justia Law

After a jury trial, Defendant was found guilty of first degree sexual assault for forcing a young woman to perform oral sex on him. Defendant appealed, arguing that his trial counsel rendered ineffective assistance in three respects. The Supreme Court affirmed Defendant’s conviction and sentence, holding that Defendant did not prove that his counsel was constitutionally ineffective for (1) seeking to introduce evidence under Wyoming’s rape shield statute; (2) failing to investigate Defendant’s “probable level of intoxication” before an interview with law enforcement; and (3) failing to object to a statement made by the prosecutor during her rebuttal closing argument. View "McGarvey v. State" on Justia Law

After a jury trial, Defendant was found guilty of three counts of second-degree sexual assault. The Supreme Court affirmed, holding (1) Defendant was not denied his right to a speedy trial; (2) the district court properly admitted forensic interview evidence as a prior consistent statement; (3) the bill of particulars was sufficient for Defendant to adequately prepare a defense; (4) the circuit court committed harmless error when it granted an ex parte motion quashing Defendant’s subpoena to call the victim and her mother as witnesses at a preliminary hearing; (5) the district court did not abuse its discretion when it denied admission of sexualized behavior evidence on relevancy and hearsay grounds; and (6) the State did not commit prosecutorial misconduct when it referenced a non-religious quote from a church sign in its opening statement.View "Ortiz v. State" on Justia Law