Justia Wyoming Supreme Court Opinion Summaries

Defendant pleaded guilty to first-degree murder, aggravated burglary, and conspiracy to commit aggravated burglary. Defendant was sixteen years old when he committed the crimes. After imposing an initial sentence, the district court resentenced Defendant to life in prison with the possibility of parole after serving for twenty-five years on the felony murder charge, to run consecutive to the previously imposed sentence for aggravated burglary of twenty to twenty-five years, and concurrent to the sentence for conspiracy to commit aggravated burglary. The Supreme Court reversed and remanded to the district court with instructions to resentence on all counts, holding that sentencing courts are required to provide an individualized sentencing hearing to weigh the factors for determining a juvenile’s diminished culpability and greater prospects for reform when, as in this case, the aggregate sentences result the functional equivalent of life without parole. Remanded for resentencing. View "Bear Cloud v. State" on Justia Law

Pursuant to a plea agreement, Defendant pled no contest to one count of interference with a police officer. The State stood by its original plea agreement at the sentencing hearing and recommended a three to five year sentence which would be suspended and Defendant would be placed on probation. The district court did not follow this recommendation and instead sentenced Defendant to incarceration of three to six years. Defendant appealed, arguing that the district court abused its discretion in sentencing. The Supreme Court affirmed, holding that the district court did not abuse its discretion in sentencing Defendant after considering Defendant’s criminal history and the safety of the community. View "Croy v. State" on Justia Law

Plaintiff filed a complaint against four defendants alleging that they conspired to fabricate a mental incompetency determination in connection with criminal proceedings filed against Plaintiff in Utah. The district court dismissed Plaintiff’s case for failing to properly serve the defendants within ninety days of filing the complaint. The Supreme Court reversed, holding (1) questions existed whether the affidavits of service on three of the defendants established a prima case of valid service, and the fourth defendant waived any objection to lack of proper service; (2) the district court did not err in failing to enter a default against the defendants; and (3) the district judge did not err in not granting Plaintiff’s motion to transfer the case to another district court. Remanded for a hearing to determine the validity of service of process. View "Lundahl v. Gregg" on Justia Law

After a jury trial, Defendant was found guilty of one count of felony child abuse. The Supreme Court affirmed, holding that the district court (1) did not violate Defendant’s right to confrontation by allegedly limiting the cross-examination of the victim regarding inappropriate sexual contact between the victim and his sister because the district court did not make a ruling on the issue; and (2) did not abuse its discretion by not granting Defendant’s motion for judgment of acquittal because there was sufficient evidence such that a jury could return a guilty verdict.View "Swan v. State" on Justia Law

After a jury trial, Appellant was convicted of aggravated assault by threatening to use a drawn deadly weapon. On appeal, Appellant argued, among other things, that his trial counsel provided ineffective assistance for failing to call an expert witness. The Supreme Court reversed and remanded for a new trial, holding (1) there was sufficient evidence to support the jury’s verdict; (2) Appellant did not receive constitutionally effective counsel, and, under the circumstances, a reasonable probability existed that, but for trial counsel’s deficient performance, the outcome would have been different; and (3) the jury was improperly instructed on self defense.View "Cooper v. State" on Justia Law

After a jury trial, Defendant was found guilty of larceny, wrongful disposal of stolen property, and burglary arising from the theft and sale of two saddles to a pawn shop. Defendant appealed, arguing that the district court abused its discretion when it admitted other bad acts evidence that Defendant pawned another saddle that allegedly belonged to her sister. The Supreme Court affirmed, holding that because the other bad acts evidence was not admitted for any proper purpose, the district court abused its discretion by allowing it into evidence, but, under the circumstances of this case, the error was harmless. View "Payseno v. State" on Justia Law

Appellant pled guilty to the federal charge of being a felon in possession of firearms. Thereafter, Appellant pled guilty at the state level to aiding and abetting burglary. The federal court sentenced Appellant to a term of imprisonment, and the state district court sentenced Appellant to a term of imprisonment to run concurrently with the federal sentence. Thereafter, Appellant filed an appeal, which he voluntarily dismissed, and two successive motions for sentence reduction, which the state district court denied and Appellant did not appeal. Appellant subsequently filed a motion to correct and illegal sentence, which the district court denied. This appeal concerned Appellant’s second motion to correct an illegal sentence. The district court denied the motion, concluding that the doctrine of res judicata applied to bar Appellant’s claim. The Supreme Court affirmed, holding that res judicata barred review of Appellant’s claim because he did not take advantage of the opportunity to raise it multiple times before. View "Dax v. State" on Justia Law

Appellant pled guilty to burglary and attempted assault on a peace officer and nolo contendre to four counts of interference with custody. The district court sentenced Appellant to prison on each of the counts but suspended the sentence in favor of supervised probation consisting of two terms: a ten-year term followed by a two-year term. The district court later found that Appellant had violated the terms of his probation, revoked probation, imposed the underlying consecutive sentences, and credited Appellant for time served. The Supreme Court affirmed the probation revocation. Thereafter, Appellant filed a pro se motion to correct illegal sentence, arguing that the first term of his probation was revoked after he had already completed it. The Supreme Court affirmed, holding (1) the doctrine of res judicata applied to bar the issue raised in Appellant’s current appeal; and (2) the district court’s revocation of Appellant’s probation was timely. View "DeMillard v. State" on Justia Law

Appellant was convicted after a jury trial of aggravated battery stemming from an altercation with his girlfriend and his girlfriend’s sister. The Supreme Court affirmed, holding (1) there was sufficient evidence to establish that the victim suffered serious bodily injury, and therefore, the jury could have determined beyond a reasonable doubt that Appellant was guilty of the crime for which he was convicted; (2) the district court did not commit plain error when it instructed the jury on the theory of self-defense; and (3) the prosecutor’s statements throughout trial were clearly improper, but Appellant was not materially prejudiced as a result of the prosecutor’s misconduct. View "Brown v. State" on Justia Law

Appellant pleaded guilty to two counts of attempted voluntary manslaughter pursuant to a plea agreement and was sentenced to two consecutive terms of incarceration of seventeen to twenty years. The Supreme Court affirmed the convictions and sentences, holding (1) the district court did not err in accepting Appellant’s guilty pleas in exchange for the plea agreement, as the plea agreement and the guilty pleas were valid; and (2) the district court did not err in sentencing Appellant in accordance with the terms of the plea agreement and in the range provided by statute.View "Noel v. State" on Justia Law