Justia Wyoming Supreme Court Opinion Summaries

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

Defendant pled guilty to felony larceny and was placed on probation subject to placement in an adult community correctional facility. Shortly after that placement, Defendant checked out of the facility and did not return. Defendant subsequently pled guilty to felony escape from official detention. The district court revoked Defendant’s probation and sentenced Defendant on both the larceny and escape convictions. A year and a half later, Defendant filed a combined Wyo. R. Crim. P. 35 motion for sentence reduction and motion for injunction seeking an order enjoining the Wyoming Board of Parole from interpreting Wyoming law in a manner that would preclude him from parole eligibility. The district court concluded that it lacked authority to rule on the motion because Defendant filed it outside the one-year period allowed for sentence reduction motions. The Supreme Court dismissed Defendant’s appeal, holding that the district court was without subject matter jurisdiction to consider Defendant’s motion on the basis that the motion was filed outside the time limits prescribed by Rule 35(b), and consequently, the Court was without jurisdiction to consider this appeal. View "Hitz v. State" on Justia Law

Appellant pled guilty to charges of strangulation of a household member, domestic battery, and reckless endangerment. The district court sentenced Appellant to three to five years on the strangulation charge to be served concurrent with a one year sentence on the domestic battery charge. Appellant subsequently filed a motion for sentence reduction based on his good behavior while incarcerated. The district court denied the motion. The Supreme Court affirmed, holding that, given the circumstances of this case and the Court’s longstanding precedent regarding sentence reduction motions based on a defendant’s behavior while incarcerated, the district court did not abuse its discretion in denying Appellant’s motion to reduce his sentence.View "Gilmer v. State" on Justia Law

Defendant entered into a conditional plea agreement pursuant to which he pled guilty to interference with a peace officer and reserved the right to appeal three issues. The district court affirmed the circuit court’s rulings on those three issues. The Supreme Court reversed after addressing only one issue that was not addressed by either party, holding (1) because one of the three issues included in Defendant’s conditional plea was not a valid pretrial motion and was therefore not reviewable in a conditional plea appeal, the entire plea was invalid; and (2) therefore, Defendant should be allowed to withdraw his conditional guilty plea. Remanded.View "Matthews v. State" on Justia Law

After a jury trial, Appellant, an inmate at the Wyoming State Penitentiary, was convicted of two counts of conspiracy to deliver a controlled substance and two counts of conspiracy to take a controlled substance into a state penal institution. The Supreme affirmed the convictions, holding (1) there was no violation of Defendant’s right to a speedy trial, where the time between Defendant’s arraignment and trial was 201 days, as the delay was part of the due administration of justice and thus did not violate Wyo. R. Crim. P. 48; and (2) the district court did not abuse its discretion when it denied Appellant’s motion to continue.View "Vargas v. State" on Justia Law

In 2011, Appellant was arrested and charged with three crimes. Appellant was on probation for crimes he had committed in 2008 at the time of his arrest, and the State also sought to revoke Appellant’s probation. Appellant and the State entered into a plea agreement, which was never reduced to writing. The district court subsequently sentenced Appellant and revoked his probation. Appellant filed a motion to correct illegal sentence and/or motion for sentence reduction, contending that the sentence imposed was not in accordance with his plea agreement and seeking modification of the sentence to conform to the terms of the plea agreement. The district court denied the motion. The Supreme Court reversed and remanded for imposition of an amended sentence, holding that the sentence imposed was not in accord with the plea agreement and was an illegal sentence because it could not be completed in a single stretch or without interruption by another prison sentence.View "Coy v. State" on Justia Law