Justia Wyoming Supreme Court Opinion Summaries

In 2011, after a jury trial, Defendant was convicted of aggravated burglary and kidnapping and found to be a habitual criminal. The district court sentenced Defendant to two concurrent life sentences. The Supreme Court affirmed the convictions and sentences. In 2013, Defendant filed a motion to correct an illegal sentence, arguing that one of the convictions the district court relied upon for the habitual criminal determination and the life sentences occurred when he was only sixteen years old and that consideration of that offense to impose a life sentence was unconstitutional under Miller v. Alabama. The district court denied Defendant’s motion to correct an illegal sentence. The Supreme Court affirmed, holding that the sentencing scheme at issue here did not mandate a life sentence for a juvenile, and therefore, Miller did not apply. View "Counts v. State" on Justia Law

Pursuant to a plea agreement, Appellant pled guilty to two misdemeanor counts of sexual battery. The district court sentenced Appellant to the maximum penalty of two consecutive one-year terms of incarceration with a portion of his sentence suspended in favor of probation. The State later filed a petition to revoke Appellant’s probation for violating the conditions of his probation. Appellant elected to represent himself during the revocation proceedings. The district court found that Appellant had violated his probation and imposed the suspended jail sentence. Appellant appealed, asserting that the district court failed to properly advise him about the dangers of representing himself in the revocation proceedings, and therefore, his decision to forego counsel was not knowing and intelligent. The Supreme Court affirmed, holding that although the advisements given by the district court did not satisfy Faretta v. California and its progeny, Appellant’s waiver of his right to counsel was knowing and intelligent. View "Reifer v. State" on Justia Law

Pursuant to a plea agreement, Appellant pleaded guilty to three counts of larceny. The plea agreement provided that Appellant would pay restitution in amounts to be determined by the district court. After a sentencing hearing, the district court ordered Appellant to pay specified amounts to several of the victims of his larceny offenses, including Range Drilling and Toni Coons. On appeal, Appellant argued that, with respect to Range Drilling, the evidence was insufficient to support any award, and with respect to Coons, the district court abused its discretion in the amount awarded. The Supreme Court reversed, holding (1) the evidence was insufficient to support the amount awarded to Coons; and (2) the district court did not err in awarding restitution to Range Drilling but erred in calculating the amount of the award. Remanded. View "Guinard v. State" on Justia Law

Appellant, an inmate, entered a plea of nolo contendere to the charge of escape. Appellant appealed that decision and subsequently filed a motion to correct an illegal sentence. The essence of Appellant’s arguments was that he should have been released from confinement on an earlier date, that any detention beyond that point was illegal, and because the crime of escape necessitates an escape from “legal” detention, his conviction was impossible and the sentence derived from it was illegal. The district court denied Appellant’s motion to correct an illegal sentence. The Supreme Court affirmed the conviction and sentence, holding (1) regarding Appellant's appeal, Appellant failed to assert a valid basis for challenging his conviction after a plea of no contest; and (2) Appellant’s challenge to his conviction was not properly asserted in a motion to correct an illegal sentence. View "Hagen v. State" on Justia Law

After a bench trial, Defendant was found guilty of one count of aggravated assault and battery for threatening to use a drawn deadly weapon against his ex-girlfriend. Defendant appealed, arguing that the State presented insufficient evidence at trial to establish beyond a reasonable doubt that he threatened to use the knife he was carrying. The Supreme Court affirmed the conviction, holding that a rational trier of fact could find that, under the circumstances, Defendant’s actions were an actual threat towards his ex-girlfriend, and therefore, there was sufficient evidence to sustain the conviction. View "Levengood v. State" on Justia Law

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