Justia Wyoming Supreme Court Opinion Summaries

Myra Jean Ford was convicted of seven counts of forgery. On appeal, Ford contended that the district court abused its discretion when it denied her motion for judgment of acquittal at the close of the State's presentation of evidence, arguing that the evidence the State produced was not sufficient to prove any of the fundamental elements of the crime of forgery. The Supreme Court reversed the district court's judgment and sentence, holding that the district court abused its discretion in denying Ford's motion for judgment of acquittal because the evidence was insufficient to prove beyond a reasonable doubt that Ford acted with the intent to defraud. Remanded with directions that the information be dismissed with prejudice. View "Ford v. State" on Justia Law

David Baker was convicted on six methamphetamine-related charges. The Supreme Court reversed his convictions on two of the charges and affimed the other four. In these consolidated appeals, Baker (1) challenged the district court's denial of his motion to correct an illegal sentence, and (2) claimed the district court erred when it did not grant him access to e-mail correspondence between the department of corrections and the public defender's office. The Supreme Court affirmed the district court's decisions, holding (1) the district court did not abuse its discretion in denying Baker's motion to correct an illegal sentence, and (2) the district court was correct in observing that Baker's motion for subpoena duces tecum asking for the requested e-mail correspondence was not appropriate in the context of Baker's criminal matter. View "Baker v. State" on Justia Law

In this termination of parental rights case, police officers found illegal drugs and drug paraphernalia in the room where Mother's two children watched television. The Department of Family Services (DFS) removed the children, placed them in foster care, and agreed on a family service plan with Mother. Mother failed to follow the requirements of her service plan. The district court subsequently terminated Mother's rights to the two children. The Supreme Court affirmed, holding that DFS proved, by clear and convincing evidence, (1) Mother was unfit to have custody and control of the children, (2) the children's health and safety would be seriously jeopardized if they returned to Mother, and (3) DFS made reasonable efforts to rehabilitate the family as required by law. View "In re A.R.C." on Justia Law

Appellant Warren Rathbun was convicted of attempted kidnapping and was sentenced to life in prison. On appeal, the Supreme Court affirmed the conviction and sentence, holding (1) Rathbun's prosecution for attempted kidnapping was not barred by the doctrine of double jeopardy due to his earlier guilty plea to battery because the two crimes each contained elements not contained in the other, and therefore, there was no preclusive effect; (2) the doctrine of res judicata neither barred the refiling of a charge for attempted kidnapping nor a subsequent preliminary hearing on the charge where there was a dismissal of the charge based upon a failure of proof of probable cause at a preliminary hearing; (3) the district court applied the proper penalty range in imposing sentence; and (4) the district court's determination of the penalty range in imposing sentence did not violate Rathbun's right to trial by jury. View "Rathbun v. State" on Justia Law

Christopher Jones pled guilty to a third battery against a household member and was sentenced to a prison term of four or five years. Jones appealed, contending that Wyo. Stat. Ann. 6-2-501(f)(ii), which prescribes the punishment for battery against a household member, was unconstitutionally vague. The Supreme Court affirmed, holding (1) Jones's argument that the statute was ambiguous did not constitute sufficient grounds to invalidate the statute as the mere fact that a statute is ambiguous is not sufficient in itself to violate the constitutional guarantee of due process; (2) the statute was not ambiguous; and (3) because the statute was unambiguous, the rule of lenity did not apply to the case. View "Jones v. State" on Justia Law

After a jury trial, Ronald Jones was convicted of felony larceny. On appeal, Jones argued that (1) the district court did not have subject matter jurisdiction over the State's larceny charge, (2) the trial court improperly instructed the jury as to the elements of larceny, and (3) there was insufficient evidence to support his conviction. The Supreme Court reversed the circuit court, holding that the failure to include the elements of taking and carrying in the jury instructions was plain error, caused material prejudice to Jones, and required reversal. In addition, the Court held that (1) the district court had subject matter jurisdiction over the offense because the charging documents set forth the elements of the alleged crime; and (2) there was sufficient evidence at trial to sustain Jones's conviction. Remanded for a new trial. View "Jones v. State" on Justia Law

After a jury trial, Michael Downing was convicted of unlawful delivery of a controlled substance. Evidence was presented at trial involving an incident wherein a confidential informant (CI), who was working with the state Division of Criminal Investigation (DCI), arranged to purchase morphine pills from Downing. In his appeal, Downing alleged that the district court abused its discretion by denying his pretrial motion seeking discovery of "other buys" in which the CI participated and by excluding at trial evidence of other such buys. The Supreme Court reversed the judgment of conviction, holding that the district court's rulings excluding evidence of the CI's other buys (1) implicated Downing's Sixth Amendment right to confront a witness and (2) were not harmless error beyond a reasonable doubt. Remanded for a new trial. View "Downing v. State" on Justia Law

Respondent Douglas Juarez was stopped by a state trooper for failing to signal his merge from an entrance ramp onto the right lane of an interstate. A subsequent search of Juarez's vehicle yielded nine pounds of marijuana. As a result, Juarez was charged with possession and possession with intent to deliver. Juarez filed a motion to suppress the search and seizure of the marijuana on the grounds that the initial traffic stop was illegal. The district court granted the motion, holding that Juarez was not required to signal his merge because Wyo. Stat. Ann. 31-5-217 did not require motorists to signal when merging onto an interstate roadway. On review, the Supreme Court affirmed, holding that (1) there is no basis in the statute to conclude that a motorist is absolutely required to signal to enter the interstate in every instance; and (2) the district court did not err in granting the motion to suppress. View "State v. Juarez" on Justia Law

Despite a divorce in 1971, appellant Christina Maycock and Bill Maycock and their children lived together as a family in a home jointly owned by the couple. In 1992, Christina, an employee of the county cemetery district, enrolled in an insurance plan that limited coverage to the district's employees, their spouses, and their dependent children. On the insurance enrollment form, Christina listed Bill as her spouse. In 2010, Christina was convicted of obtaining property by false pretenses because of her alleged misrepresentation on the insurance enrollment form. Christina appealed, challenging the legal sufficiency of the evidence supporting her conviction. The Supreme Court held that there was insufficient evidence to sustain Christina's conviction. The Court then reversed the conviction, concluding that there was no evidence on the record that Christina's misrepresentation was the determining factor in the board's decision to pay the cost of insuring Bill. Remanded. View "Maycock v. State" on Justia Law

Appellant Kelly Robinson was convicted of three misdemeanors and one felony. All of the crimes arose in a domestic violence context. One of Robinson's misdemeanor convictions was the violation of a protection order, which resulted from Robinson mailing a letter to the victim, who had obtained a protection order. Robinson challenged his conviction for violation of the protection order, claiming that there was insufficient evidence to sustain a conviction for the crime charged. On appeal, the Supreme Court found that the record on appeal lacked evidence to support the conviction as charged. Because the circuit court found that Robinson's conduct constituted stalking as defined by Wyo. Stat. Ann. 6-2-506(b), the trial court erred in convicting Robinson under Wyo. Stat. Ann. 6-4-404(b). Because of the error, the Court reversed the conviction entered pursuant to Section 6-4-404, and affirmed the remainder of the judgment. Remanded. View "Robinson v. State" on Justia Law