Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s conviction of first-degree felony murder but vacated Appellant’s sentence for the aggravated burglary conviction, the underlying felony. The court held (1) the district court did not err in refusing to instruct the jury that self-defense could be raised as a defense to a charge of felony murder; (2) the district court did not abuse its discretion in denying Appellant’s request to instruct the jury on the definition of the phrase “in the perpetration of” as used in Wyo. Stat. Ann. 6-2-101; but (3) the district court’s issuance of convictions for felony murder and aggravated burglary, the underlying felony, violated protections against double jeopardy. View "Schnitker v. State" on Justia Law

The Supreme Court affirmed the Medical Commission’s denial of additional temporary total disability benefits to Appellant. The Commission denied benefits after a contested case hearing, concluding that Appellant’s persistent back problems were the result of a preexisting degenerative condition and that Appellant failed to establish an increase in incapacity to a reasonable degree of medical certainty due solely to a work injury. The district court upheld the Commission’s decision. The Supreme Court affirmed, holding (1) there was substantial evidence to support the Commission’s conclusion that Appellant was not entitled to benefits under Wyo. Stat. Ann. 27-14-605; (2) the Commission did not misapply the second compensable injury rule; and (3) there was substantial evidence to support the Commission’s conclusion that Appellant did not suffer a second compensable injury. View "Kebschull v. State ex rel. Department of Workforce Services, Workers’ Compensation Division" on Justia Law

The Supreme Court affirmed the convictions of Appellants, Michael Tibbets and Donna Gifford, each of three counts of child abuse in relation to injuries inflicted upon their children. The district court sentenced Appellants to terms of three to five years for each count, to be served consecutively, but suspended all but Appellants’ first year of confinement in favor of supervised probation. On appeal, Appellants argued that the Sate produced insufficient evidence to support the convictions. The Supreme Court disagreed, holding that the State produced sufficient evidence to prove beyond a reasonable doubt that Appellants recklessly caused mental injury to their children, which was sufficient to sustain their convictions for child abuse under Wyo. Stat. Ann. 6-2-503(b)(ii). View "Gifford v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions of one count of first degree sexual abuse of a minor and one count of second degree sexual abuse of a minor but reversed and remanded for resentencing on Defendant’s first degree sexual abuse conviction. The court held (1) the district court did not err when it denied Defendant’s motion to suppress his statements to law enforcement because Defendant did not make an adequate request for counsel; (2) the district court violated a clear and unequivocal rule of law by allowing the police interview of Defendant to be played to the jury, but Defendant was not prejudiced; (3) the district court did not abuse its discretion when it quashed a subpoena duces tecum without conducting an in camera review of the material; and (4) Defendant was entitled to be resentenced on Count II because it violated Wyo. Stat. 7-13-201. View "Hathaway v. State" on Justia Law

Employee was terminated from her position as a custodian at a junior high school for stealing or attempting to steal a backpack belonging to a student. The Board of Trustees of Sweetwater County School District No. 1 (Board) upheld Employee’s termination, concluding that there was cause to terminate Employee and there was no prejudice from any claimed defect in the predetermination process. The district court reversed, concluding (1) there was substantial evidence to support the Board’s determination that there was just cause to terminate Employee, but (2) Employee was not provided adequate predetermination process. The Supreme Court reversed the district court’s decision and reinstated the Board’s order upholding the termination, holding that the Board’s decision that Employee received adequate predetermination due process was legally correct and supported by substantial evidence. View "Sweetwater County School District Number One v. Goetz" on Justia Law

Appellant pled guilty to third-degree sexual abuse of a minor. The district court accepted the guilty plea and imposed five years of supervised probation. Appellant later filed a motion to withdraw his guilty plea, arguing that he had received ineffective assistance of counsel and was prejudiced because he would not have pled guilty were it not for counsel’s deficient performance. The district court denied the motion. The Supreme Court affirmed, holding that counsel’s performance was not deficient, and therefore, the district court did not abuse its discretion in denying Appellant’s motion to withdraw his guilty plea. View "Berger v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of theft, rendered after a jury trial. On appeal, Defendant argued that the prosecutor committed misconduct when he mentioned Defendant’s race during rebuttal closing arguments. Specifically, Defendant argued that, in doing so, the prosecutor attempted to appeal to the racial bias of the jury. The Supreme Court held (1) when the prosecutor commented on Defendant’s race, he was doing so in response to defense counsel’s suggestion that race was an issue; and (2) therefore, there was no prosecutorial misconduct committed in this case and no plain error committed by the trial court. View "Cole v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions for three counts of first-degree sexual abuse of a minor and one count of second-degree sexual abuse of a minor. On appeal, Defendant argued that the district court abused its discretion in denying his motion for new trial based on the admission of photographs depicting the child victim’s vagina, on the court’s refusal to play Defendant’s entire law enforcement interview, on improper opinion testimony from a nurse practitioner, and on the prosecutor’s comment during closing argument. The Supreme Court held (1) the district court properly denied Defendant’s motion for new trial; and (2) because Defendant failed to establish any underlying errors or prejudice from any alleged errors, his claim of cumulative error failed. View "Carrier v. State" on Justia Law

The Supreme Court affirmed the ruling of the district court concluding that the probationary portion of a sentence imposed by the municipal court upon Respondent was illegal. Respondent entered a no contest plea to violating Casper Municipal Code 5.08.370(A) and (B). The municipal court sentenced Respondent to, in addition to a fine, six months of unsupervised probation. The district court reversed the municipal court’s sentence, concluding that it was illegal because the Casper ordinances governing the penalty for the possession of alcohol by a minor expressly limited that penalty to a fine and did not provide for a potential penalty of incarceration. The Supreme Court agreed, holding that the district court did not err in concluding that when no confinement is expressly authorized as a punishment for a particular offense, a sentencing court also lacks the authority to impose a period of probation upon a conviction for such an offense. View "City of Casper v. Simonson" on Justia Law

Bruce Williams submitted a public records request to the Campbell County Sheriff’s office requesting a list of the weapons or implements carried on persons of police officers involved in the killing of Niki Jo Burtsfield. After the Sheriff’s office responded, Williams made further inquiry, believing he was not provided all of the documents he requested. Thereafter, Williams filed a “petition for reasonable response” pursuant to Wyo. Stat. 16-4-202(b) and (c). The district court granted summary judgment for Scott Matheny, the Campbell County Sheriff. The Supreme Court affirmed, holding that because the Sheriff had, at the time of the district court’s ruling, provided the information that Williams requested, this inquiry was moot. View "Williams v. Matheny" on Justia Law