Justia Wyoming Supreme Court Opinion Summaries

Appellant pled no contest to charges of larceny, burglary, and possession of a controlled substance with intent to deliver. Appellant later filed a motion to correct an illegal sentence, arguing that his sentence was illegal because he had not received credit for the time he spent in the county jail after he was sentenced but before he was transferred to a Wyoming Department of Corrections facility. The district court denied the motion. The Supreme Court affirmed, holding that Appellant’s claim was not one properly raised in a motion to correct an illegal sentence under Wyo. R. Crim. P. 35. View "Candelario v. State" on Justia Law

Defendant stole a car in Thermopolis and drove it toward Colorado. Defendant was arrested and jailed in Colorado. The State of Wyoming charged Defendant in Laramie County with receiving stolen property and in Hot Springs County with larceny. The State filed detainers in Colorado pursuant to the Interstate Agreement on Detainers (IAD), and Defendant requested deposition of the charges against him in both counties. Because the State failed to try Defendant within the 180-day period required by the IAD, the Laramie County charges were dismissed with prejudice. The State again failed to timely bring Defendant to trial, and the Hot Springs County charge was dismissed with prejudice. Defendant was then transported back to Colorado. The State then filed another charge against Defendant in Hot Springs County for receiving stolen property. A jury convicted Defendant. The Supreme Court reversed, holding that the dismissal of the Laramie County charge with prejudice barred the State from charging Defendant with the same crime in Hot Springs County. View "Webster v. State" on Justia Law

Mother and Father shared custody of their child pursuant to a custody order that provided for the parties to alternate custody on a weekly basis. The custody order included a drug testing requirement allowing Mother to make one request per month that Father submit to a drug test. If the test is negative, Mother must reimburse Father for the cost of the test before making another request. Father later filed a show cause motion alleging that Mother had violated the order by failing to allow him his visitation and reimburse him for a negative test. Mother filed her own show cause motion alleging that Father violated the drug testing requirement. The district court granted Father’s motion and denied Mother’s motion and ordered Mother to pay Father’s attorney fees and the costs of the negative drug test. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in finding that Father did not violate the custody order; and (2) erred in finding that Mother willfully violated the custody order, but the court’s granting of relief is nevertheless upheld because Mother’s conduct did deprive Father of visitation and reimbursement of drug testing costs to which he was entitled under the custody order. View "JLK v. MAB" on Justia Law

After a jury trial, Appellant was convicted of one count of burglary. Appellant was sentenced to eighteen to thirty-six months in prison. The Supreme Court affirmed, holding (1) Appellant failed to meet his burden of proving that he was prejudiced by the admission of what he contended was uncharged misconduct evidence; and (2) the State did not commit prosecutorial misconduct rising to the level of plain error in its closing argument, as it could not be said Defendant would have received a more favorable verdict if the comment had not been made. View "Wiese v. State" on Justia Law

Appellees, the purported owners of the “Jay Ranch,” brought an action against Appellant to establish a private road across Appellant’s property. While this suit was pending, Appellees were involved in litigation to determine the rightful ownership the Jay Ranch. The district court concluded that Appellees had satisfied the statutory threshold requirements to move forward with their private road claim and granted Appellees temporary access to the road across Appellant’s property. Thereafter, a decision was rendered against Appellees in the litigation to determine ownership of the Jay Ranch. The district court subsequently dismissed the present case for lack of prosecution. Appellant filed a motion for an award of attorney’s fees and a motion for an award of compensation for the temporary road access. The district court denied both motions. The Supreme Court dismissed Appellant’s appeal, holding (1) Appellant’s post-judgment motion for attorney’s fees was not authorized under Wyo. R. Civ. P. 54; and (2) the district court did not have jurisdiction to consider Appellant’s motion for compensation. View "Edsall v. Moore" on Justia Law

After a jury trial, Defendant was convicted of driving under the influence of alcohol. During the trial, the district court allowed the State to introduce expert testimony involving retrograde extrapolation to prove that Defendant’s blood alcohol level was above the legal limit of 0.08 percent while he was driving on the night in question. Defendant did not object to the admission of the testimony at trial. On appeal, Defendant challenged the admission of the retrograde extrapolation evidence. The Supreme Court affirmed, holding that Defendant failed to establish that he was prejudiced by admission of the challenged evidence. View "Young v. State" on Justia Law

Defendant was charged with conspiracy to deliver a controlled substance, unlawful possession of a controlled substance, and obstruction of a peace officer. Defendant filed a motion to suppress, arguing that the stop of his vehicle was unlawful. The district court denied the motion, concluding that the traffic stop and investigatory detention of Defendant were reasonable. Defendant entered a conditional guilty plea to all three charges. The Supreme Court affirmed, holding that the district court did not err when it denied Defendant’s motion to suppress evidence, as the information available to the officer at the time he made the traffic stop could give rise to a reasonable suspicion of criminal activity. View "Jennings v. State" on Justia Law

In 1995, Appellant pled guilty to second-degree murder and was sentenced to twenty-eight years to life. In 2015, Appellant filed a pro se motion to correct an illegal sentence, claiming that his sentence was illegal because the district court failed to provide a firearms disqualification advisement at the time of sentencing. The district court denied the motion, concluding (1) the advisement statute, Wyo. Stat. Ann. 7-11-507, was not applicable to Appellant’s case because the statute was not enacted until 2009; and (2) Appellant’s sentence was permitted under Wyo. Stat. Ann. 6-2-104. Appellant appealed, presenting several claims in support of his contention that his sentence was illegal. The Supreme Court affirmed, holding that the district court did not err in its decision to deny Appellant’s motion to correct illegal sentence. View "Barela v. State" on Justia Law

Appellants, the owners of a tract of land in the Riva Ridge subdivision, submitted their plans to build a home and writer’s studio to the Riva Ridge Owners Association’s Site Committee. The Site Committee rejected the plans on the basis that some of Appellants’ home would be visible from some locations in other homes. Appellants filed a complaint against the Association and others (collectively, Appellees) alleging several causes of action. Appellants filed a separate complaint requesting a determination of the term “principal residence site” in the covenants. The district court granted summary judgment for Appellees on several issues. After a trial, the district court interpreted the phrase “principal residence site” in a way that required complete invisibility between the homes in the subdivision. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) erred in its interpretation of the phrase “principal residence,” as the covenants only require that a principal residence be invisible only from a precise area of land on each tract; (2) erred in granting summary judgment on Appellants’ breach of contract and bad faith claims; and (3) properly determined that Appellants must seek permission from the Site Committee before planting any trees on their tract. View "Felix Felicis, LLC v. Riva Ridge Owners Ass’n" on Justia Law

After a jury trial, Defendant was convicted of possessing small amounts of morphine and methamphetamine. The offenses were felonies due to Defendant’s prior controlled substance convictions. The district court sentenced Defendant to concurrent sentences of two to five years in prison. The Supreme Court affirmed the convictions and sentence, holding (1) Defendant’s counsel was not ineffective for failing to move to suppress the evidence found during the warrantless search of Defendant’s backpack; (2) the evidence was sufficient to support Defendant’s convictions; and (3) the district court properly rejected Defendant’s request for an additional instruction on constructive possession. View "Lemley v. State" on Justia Law