Justia Wyoming Supreme Court Opinion Summaries

Defendant was charged with making a false statement to obtain welfare benefits. Pursuant to a plea agreement, Defendant pled guilty to amended charge of misdemeanor interference with a peace officer and agreed to pay restitution in an amount to be determined after Defendant’s codefendant went through her plea or trial. Nearly two years after Defendant’s plea and sentencing, the district court issued a ruling requiring Defendant to pay restitution in the amount of $2,600. The Supreme Court reversed and vacated the restitution order, holding that the order was not supported by sufficient evidence, as the State presented no evidence that Defendant received or otherwise benefited from a welfare fraud scheme in the amount of $2,600. View "O'Halloran v. State" on Justia Law

After a jury trial, Defendant was convicted of one count of first degree murder and sentenced to life imprisonment. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in deciding to overrule Defendant’s objection to the court’s admission of certain testimony, as the evidence was not, as Defendant alleged, uncharged misconduct in violation of Wyo. R. Evid. 404(b); (2) the prosecutor did not commit misconduct during closing argument; and (3) the district court did not err in failing to instruct the jury in accordance with the Court’s decision in Eagan v. State.View "Gonzalez-Ochoa v. State" on Justia Law

After a jury trial, Appellant was convicted of felony driving while under the influence of alcohol. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in denying in part a pretrial discovery request made by Appellant; (2) the district court did not violate Appellant’s constitutional right to confrontation when the State’s expert witness testified as to the operation, maintenance, and accuracy of the breath alcohol test machine used in this case; and (3) Appellant’s trial counsel was not ineffective in not calling an expert witness to testify as to the effect of diabetes on the results of a breath alcohol test.View "Anderson v. State" on Justia Law

After a jury trial, Appellant was convicted for possession, delivery, and conspiracy to deliver methamphetamine. On appeal, Defendant challenged the admission of photographic evidence of items in his home containing methamphetamine, arguing that the evidence constituted evidence of uncharged misconduct under Wyo. R. Evid. 404(b) because it suggested that Appellant was manufacturing methamphetamine. The State responded that the evidence was substantive evidence of the crimes charged and was thus not uncharged misconduct evidence. The Supreme Court affirmed the convictions, holding that the district court did not abuse its discretion in admitting the challenged evidence because it was intrinsic to the crimes charged and was not uncharged misconduct evidence. View "Hernandez v. State" on Justia Law

Defendant entered Alford pleas to promoting prostitution, conspiracy to commit first degree sexual assault, and aggravated assault and battery on a pregnant woman. The victim in this case was Defendant’s girlfriend. The district court imposed suspended sentences of incarceration and ten years probation to run consecutively with a term of imprisonment for the conspiracy charge. One of the conditions of Defendant’s probation was that Defendant have no contact with the victim of the offense or the minor children of the victim and Defendant. Defendant appealed, arguing that the “no contact” condition of his probation was not reasonably related to his rehabilitation and was an encroachment upon his fundamental right to raise his children. The Supreme Court affirmed, holding that the district court did not abuse its discretion in imposing the “no contact” condition of probation in Defendant’s sentencing. View "Perkins v. State" on Justia Law

After an investigation, police learned that Defendant, a band teacher, had sexual relations with three students at Rock Springs High School. The State charged Defendant with a total of fifteen counts of sexual abuse of a minor. Pursuant to a plea deal, Defendant pleaded guilty to three counts, and the State dismissed the remaining charges. At the sentencing hearing, several students, including two of the victims, testified on Defendant’s behalf. The district court sentenced Defendant to a fifteen to twenty-five-year sentence for one count of sexual abuse of a minor in the first degree, to be served concurrently with the sentences imposed on the other counts. The Supreme Court affirmed, holding that the district court (1) properly exercised its discretion in sentencing Defendant and in considering statements made by the victims as aggravating rather than mitigating; and (2) did not violate Defendant’s due process rights when it recessed his sentencing hearing and continued it to the next day. View "Thompson v. State" on Justia Law

Appellant was convicted of felony child abuse for physically abusing his fifteen-year-old daughter during a heated conversation about the daughter’s poor grades. The statute under which Appellant was convicted expressly provides that a defendant is not guilty of child abuse if the physical injury results from “reasonable corporal punishment.” Appellant argued that the jury instructions in this case were faulty because the district court failed properly to instruct the jury as to the elements of felony child abuse because the jury was not instructed that the State must prove beyond a reasonable doubt that the physical injury was not the result of discipline Appellant was permitted to administer. The Supreme Court reversed and remanded for a new trial, holding that district court failed properly to instruct the jury on the elements of felony child abuse, and the court’s error created confusion as to the burden of necessary elements of the crime and the burden of proof, resulting in prejudice to Appellant. View "Andersen v. State" on Justia Law

Defendant pleaded guilty to first-degree felony murder and aggravated burglary. Defendant was sentenced to life imprisonment on the murder charge. Defendant did not appeal his conviction. Instead, Defendant filed several motions and petitions concerning his conviction and sentence, to no avail. Here Defendant filed a number of motions challenging his sentence, claiming that it was illegal because in 2013 he was transferred from Wyoming to Virginia to serve out his sentence. The district court denied Defendant’s motions. The Supreme Court affirmed, holding that because Defendant challenged the way in which the State executed his sentences, rather than the legality of his sentences, his transfer to Virginia did not constitute an illegal sentence. View "Garnett v. State" on Justia Law

Defendant pleaded guilty to driving while under the influence of alcohol (DWUI). This was Defendant’s fourth such offense within the previous ten years, making it a felony under Wyo. Stat. Ann. 31-5-233(e) and subject to a sentence enhancement. Defendant filed a motion to strike two of four prior convictions, claiming that the two prior DWUI convictions were not constitutionally obtained and therefore should not have been relied upon for sentence enhancement purposes. The district court denied Defendant’s motion, ruling that because Defendant had not appealed from his earlier convictions the convictions could not be overturned. The court then enhanced Defendant’s conviction to a felony and sentenced Defendant accordingly. The Supreme Court affirmed Defendant’s enhanced sentence, holding that Defendant’s underlying convictions were constitutionally obtained. View "Derrera v. State" on Justia Law

Defendant pled guilty to one count of solicitation to commit property destruction. On appeal, Defendant argued (1) the district court lacked subject matter jurisdiction because he was in West Virginia at the time of the alleged solicitation, and (2) he received ineffective assistance of counsel. The Supreme Court affirmed, holding (1) the State had subject matter jurisdiction to prosecute Appellant for charges specified in the charging Information, as Defendant intended his criminal actions to have an effect in Wyoming; and (2) Appellant failed to carry his burden of showing that his representation by trial counsel was so ineffective that it rendered Appellant’s guilty plea involuntary. View "Turner v. State" on Justia Law