Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the juvenile court placing MBP, a juvenile, on supervised probation for three to six months after adjudicating him delinquent for fighting in public, holding that the juvenile court did not err in either its adjudication or order of disposition.As part of the disposition, the juvenile court placed MBP on supervised probation for three to six months. MBP appealed, arguing that the evidence was insufficient establish to support the adjudication and that the sentence imposed was contrary to law. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the requisite intent and established an implicit agreement to fight; and (2) MBP failed to establish that the juvenile court's imposition of a three-to-six-month probationary term constituted plain error. View "MBP v. State" on Justia Law

The Supreme Court reversed the judgment of the juvenile court denying RH's petition for expungement of his record pursuant to Wyo. Stat. Ann. 14-6-241, holding that the district court erred in interpreting sections 14-6-241(d) and (e).When RH was sixteen years old the State filed a delinquency petition against him. RH agreed to a deferred prosecution and successfully completed the terms of his deferral. Thereafter, the juvenile court dismissed the delinquency petition. RH later petitioned for expungement of his record. The juvenile court denied the petition, concluding that RH was statutorily ineligible to have the record expunged because the petition charged him with a violent felony. The Supreme Court reversed, holding that section 14-6-241 allows expungement of a juvenile record where a delinquency petition was dismissed but the delinquent act charged was a violent felony. View "RH v. State" on Justia Law

The Supreme Court reversed Defendant's conviction for third-degree sexual assault and false imprisonment, holding that the district court erred in denying Defendant's motion to transfer his case to juvenile court.Defendant was eighteen years old when the State charged him with offenses that he allegedly committed when he was seventeen years old. When Defendant moved to transfer his case to juvenile court, the State argued that the juvenile court lacked concurrent jurisdiction because Defendant was an adult when the charges were filed against him. The district court dismissed Defendant's transfer motion, concluding that the juvenile court's jurisdiction depended on Defendant's age when he was charged rather than his age when he committed the offense at issue. The Supreme Court reversed, holding that a juvenile court's concurrent jurisdiction under Wyo. Stat. Ann. 14-6-203(c) depends on an offender's age at the time of the offense, rather than at the time charges are filed. View "Rosen v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to transfer his case to juvenile court, holding that the district court did not abuse its discretion in denying the motion to transfer the case to juvenile court.Defendant, a minor, was arrested and charged with nine counts of attempted first-degree minor after taking guns and ammunition to his high school planning to shoot nine particular individuals and as many other people as he could. Defendant filed a motion to transfer his case to juvenile court, but the motion was denied. The Supreme Court affirmed, holding that the district court appropriately analyzed and weighed the applicable factors under Wyo. Stat. Ann. 14-6-237(b) and did not abuse its discretion in denying Defendant's motion to transfer. View "Warner v. State" on Justia Law

The Supreme Court reversed the district court’s denial of Defendant’s motion to modify his original sentence after a new individualized sentencing hearing and remanded for a new individualized sentencing hearing.Defendant was seventeen years old when he and his friend robbed and murdered a hitchhiker. Defendant was sentenced to life imprisonment with a consecutive twenty-to-fifty-year sentence for aggravated robbery. Following the decisions in Miller v. Alabama, 567 U.S. 460 (2012), Montgomery v. Louisiana, __ U.S. __ (2016), and Bear Cloud v. State, 294 P.3d 36 (Wyo. 2013), and the Wyoming Legislature’s amendment to Wyo. Stat. Ann. 6-10-301(c), Defendant was granted parole from his life sentence and began serving his consecutive twenty-to-fifty-year sentence. Defendant received a new individualized sentencing hearing, after which the district court declined to modify Defendant’s original sentence. The Supreme Court reversed and remanded for an additional sentencing hearing because at the time of the hearing and the district court’s decision, the parties and the district court did not have the advantage of this Court’s rulings concerning the procedure, burdens, and potentially relevant evidence for a Miller determination contained within this opinion. View "Davis v. State" on Justia Law

Defendant was sixteen years old when he committed the crimes at issue in this case. The Supreme Court affirmed Defendant’s convictions of one count of first-degree murder, one count of aggravated assault and battery, and ten counts of attempted aggravated assault and battery but reversed Defendant’s sentence and remanded for resentencing. The court held (1) the district court did not abuse its discretion when it denied Defendant’s motion to transfer the proceedings to juvenile court; (2) there were some errors in the jury instructions, but the errors were not prejudicial either individually or cumulatively; (3) the prosecutor’s victim impact statements during closing arguments were improper but not prejudicial; (4) there was sufficient evidence to support the attempted assault and battery charges; (5) Defendant’s aggregate sentence did not deprive the parole board of its statutory authority to consider parole of juveniles after twenty-five years; (6) Defendant’s sentence for murder and aggravated assault of the same victim did not violate double jeopardy; but (7) Defendant’s aggregate sentence violated the Eighth Amendment because it was a de facto life without parole sentence. View "Sam v. State" on Justia Law

Appellant was adjudicated a delinquent juvenile for committing a sexual offense that required him to register as an offender under the Wyoming Sexual Offender Registration Act (WSORA). Appellant later entered a conditional guilty plea to two felony counts for failing to report changes in his address, as required by the WSORA. Appellant appealed his convictions, claiming that the WSORA is unconstitutional. The Supreme Court affirmed, holding (1) the Wyoming Juvenile Justice Act does not conflict irreconcilably with the WSORA’s registry requirements for adjudicated juvenile offenders; (2) the WSORA does not violate the Wyoming Constitution’s equal protection clause; (3) Appellant failed to establish that the WSORA’s lifetime registration requirement violates his due process rights; and (4) the WSORA does not violate the ex post facto clause of the United States Constitution. View "Vaughn v. State" on Justia Law

Appellant, a juvenile, was convicted and sentenced. The Supreme Court reversed Appellant’s sentence, instructing that, if a sentence of life according to law was imposed, the district court must specify a period of parole ineligibility. The district court did as instructed and imposed a sentence of life according to law with the specification that Appellant was eligible for parole on the sentence after thirty-five years. The Supreme Court vacated the sentence imposed by the district court, holding that Appellant should be resentenced because the district court did not consider the analysis from Miller v. Alabama “in light of the entire sentencing package.” View "Sen v. State" on Justia Law

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

MF was adjudicated a child in need of supervision (CHINS) shortly before his sixteenth birthday. Four months before MF's seventeenth birthday and after MF twice violated his probation, the juvenile court ordered that MF remain in the custody of the Department of Family Services and on probation until his eighteenth birthday. MF appealed, arguing that any CHINS order must terminate when the minor child turns seventeen. The Supreme Court reversed and vacated the juvenile court's order to the extent the order purported to have effect beyond MF's seventeenth birthday, holding that the juvenile court did not have the authority to issue a CHINS order that imposed conditions beyond MF's seventeenth birthday. View "In re MF" on Justia Law