Justia Wyoming Supreme Court Opinion Summaries

In this case, law enforcement officers responded to a domestic disturbance at a residence where they found the defendant holding his pregnant fiancée by the wrists. The officers directed him to remain seated on the kitchen floor during their investigation, which lasted about forty minutes. During this time, the defendant was told he was not under arrest but was not free to leave. He eventually admitted to restraining his fiancée by the chin and neck and taking her to the ground. He was later arrested and charged with several offenses, including aggravated assault and battery.After a preliminary hearing in the Circuit Court, the case was bound over to the District Court of Albany County. The defendant moved to suppress statements made before his formal arrest, arguing they were obtained during a custodial interrogation without Miranda warnings. The State opposed, contending he was not in custody until his formal arrest. The District Court held a hearing, denied the motion to suppress, and accepted the defendant’s conditional guilty plea to aggravated assault, reserving his right to appeal the suppression ruling.On appeal, the Supreme Court of Wyoming reviewed whether the conditional guilty plea was valid under Rule 11(a)(2) of the Wyoming Rules of Criminal Procedure. The Court found that, although the plea was in writing, and both the State and the District Court approved it, the issue reserved for appeal—suppression of the defendant’s statements—was not dispositive. Independent evidence existed that could support conviction even if the statements were suppressed. Because the reserved issue was not dispositive, the conditional plea was invalid.The Supreme Court of Wyoming vacated the judgment of conviction and reversed and remanded the case to the District Court for further proceedings. The main holding is that a conditional guilty plea is invalid if the issue reserved for appeal is not dispositive of the entire case. View "Kotrc v. The State of Wyoming" on Justia Law

A five-year-old child died after being left in the care of the defendant, who was the only adult present at the time. The defendant called 911, reporting the child had fallen down the stairs and was unresponsive. Emergency responders observed significant bruising and signs of oxygen deprivation. The child was transported to a hospital and died the next day. Law enforcement, suspecting abuse, interviewed the defendant at the police station. The defendant was advised of her Miranda rights, acknowledged understanding them, and agreed to speak with officers. Over several hours, during which she was allowed breaks and was not under arrest, the defendant ultimately confessed to beating the child and admitted fabricating the story about a fall.The State charged the defendant with first-degree murder and child abuse. The defendant moved to suppress her confession, arguing it was involuntary due to custodial circumstances, her use of prescription medication, and an invalid Miranda waiver. The District Court of Lincoln County held a suppression hearing without the defendant present, as she was hospitalized, and her counsel consented to proceeding in her absence. The court found the confession voluntary, denied the suppression motion, and admitted the confession at trial. The jury convicted the defendant on both charges.On appeal, the Supreme Court of the State of Wyoming reviewed whether the district court erred in finding the confession voluntary and in conducting the suppression hearing without the defendant present. The Supreme Court held that, under the totality of the circumstances, the confession was voluntary and not the result of coercion or impairment. The court also found that any error in holding the suppression hearing without the defendant was harmless, as there was no reasonable probability her presence would have changed the outcome. The convictions and rulings of the district court were affirmed. View "Marler v. The State of Wyoming" on Justia Law

A nineteen-year-old man was convicted for his involvement in two murders in Wyoming. He was sentenced in 2006 to three consecutive terms of life imprisonment without the possibility of parole, following a jury trial in which he was acquitted of one count of first-degree murder but convicted of conspiracy to commit murder and first-degree murder for the other offenses. The crimes involved the killing of a roommate and a sixteen-year-old, with the defendant playing a significant role in both. At sentencing, the jury declined to impose the death penalty and instead issued mandatory life without parole sentences, as required by Wyoming law at the time.After his direct appeal was denied by the Wyoming Supreme Court, the defendant filed a motion in 2024 to correct his sentences, arguing that mandatory life without parole for “emerging adults” (those aged eighteen to twenty-one) is unconstitutional under both the Wyoming and United States Constitutions. He claimed that new scientific evidence and evolving legal standards, particularly those established in Miller v. Alabama and related U.S. Supreme Court cases, should extend protections against mandatory life without parole to offenders in his age group. The District Court of Campbell County denied his motion, finding that the relevant constitutional protections and precedents did not apply to adults over eighteen.The Supreme Court of Wyoming reviewed the case and affirmed the district court’s decision. The court held that the Wyoming Constitution does not provide broader categorical protections for “emerging adults” than the Eighth Amendment. It concluded that the state’s constitutional provisions on cruel or unusual punishment and on the penal code’s humane principles do not prohibit mandatory life without parole sentences for offenders over eighteen. The court also found no violation of equal protection or entitlement to a new sentencing hearing. The holding clarified that, while Wyoming’s constitution is distinct from the federal constitution, it does not require categorical relief for emerging adults sentenced to life without parole. View "Hicks v. The State of Wyoming" on Justia Law

The case concerns a man who, after being separated from his wife of six months, engaged in repeated and escalating contact with her, including hostile voicemails, text messages, and physically aggressive behavior such as banging on her door and damaging property. After being served with divorce papers, his conduct intensified, including following her, driving by her residence and her mother’s house, and sending threatening messages. One particular text message stated he had “nothing to lose,” would “go back to prison,” and would “die before I go back.” Law enforcement was contacted, and during a recorded conversation with an officer, he again referenced the possibility of returning to prison.The District Court of Sheridan County charged him with felony stalking, based on his conduct and a prior stalking conviction. The prosecution sought to introduce evidence under Wyoming Rule of Evidence 404(b), including the text and recorded statement referencing prison, to show intent, motive, and consciousness of guilt. The district court held a hearing, conducted the required analysis under Gleason v. State, and admitted the text and recorded statement for the stated purposes, while excluding other references to his prior conviction. At trial, the jury found him guilty, and he was sentenced to four to eight years in prison.On appeal, the Supreme Court of Wyoming reviewed whether the district court abused its discretion in admitting the text and recorded statement under W.R.E. 404(b). The court held that the district court properly admitted the evidence, as it was relevant to show intent, motive, and consciousness of guilt, and its probative value was not substantially outweighed by unfair prejudice. The Supreme Court of Wyoming affirmed the conviction. View "Bragdon v. The State of Wyoming" on Justia Law

A man who operated an outfitting and hunting guide business was married to the defendant from 2019 to 2021. After their divorce, he learned that his hunting and guiding privileges had been suspended in both Idaho and Wyoming due to a misdemeanor hunting violation. In 2022, he alleged that his ex-wife made false and damaging statements about him to members of their small community, including claims that he was a convicted felon, a homosexual, a poacher, and attracted to underage girls. He attributed several negative consequences in his personal and professional life to these alleged statements and filed a lawsuit against his ex-wife for defamation per se.The District Court of Park County reviewed the case after the defendant moved for summary judgment, arguing there was no genuine dispute of material fact because she denied making the statements and the plaintiff had no evidence to the contrary. The district court agreed and granted summary judgment in her favor, dismissing the defamation per se claim. The plaintiff appealed, contending that there was admissible evidence—specifically, an affidavit from a third party who swore the defendant made the statements—to create a genuine issue of material fact.The Supreme Court of Wyoming reviewed the district court’s decision de novo. The court held that the affidavit from the third party was competent, admissible evidence and not hearsay, and that it directly contradicted the defendant’s denial. The court clarified that imputing a criminal offense is a separate and sufficient basis for defamation per se under Wyoming law. Because a genuine issue of material fact existed as to whether the defendant made the alleged statements, the Supreme Court of Wyoming reversed the district court’s summary judgment and remanded the case for trial. View "Lewis v. Francis" on Justia Law

A defendant was charged with two counts of second-degree sexual abuse of a minor and one count of third-degree sexual abuse of a minor, based on allegations that he engaged in sexual acts with a 15-year-old girl. The alleged conduct included both acts of sexual intrusion and other sexually related behavior. The defendant denied any sexual contact, while the victim and another witness provided testimony about the events. Forensic evidence was inconclusive, and the defendant’s police interview was played for the jury. The jury acquitted the defendant on the two counts of second-degree sexual abuse but convicted him on the third-degree charge.The District Court of Natrona County conducted the trial and provided jury instructions that did not specifically exclude conduct that would qualify as first- or second-degree sexual abuse from the third-degree charge, nor did they specify the factual basis for the third-degree charge. Defense counsel agreed to the instructions as given and specifically requested that the instructions not exclude the conduct alleged in the other counts. After the jury returned its verdict, the defendant appealed, arguing that the jury instructions were erroneous for not excluding first- or second-degree conduct from the third-degree charge and for failing to specify the conduct underlying the third-degree charge.The Supreme Court of Wyoming reviewed the case. It held that the defendant had affirmatively waived any objection to the lack of an instruction excluding first- or second-degree conduct from the third-degree charge by requesting that such language be omitted, invoking the invited error doctrine. The court further held that the district court did not plainly err by failing to specify the factual basis for the third-degree charge in the jury instructions, as there was no clear and unequivocal rule of law requiring such specificity when only a single count was at issue. The Supreme Court of Wyoming affirmed the conviction. View "Townsend v. The State of Wyoming" on Justia Law

Law enforcement officers stopped an individual for a traffic violation and, during the stop, discovered a small amount of cocaine and marijuana in his vehicle, along with over $23,000 in cash hidden in various locations. After his arrest, the individual admitted to law enforcement that he had purchased and distributed controlled substances and that about half of the seized money was from drug sales, with the remainder allegedly from a 401k and insurance settlement. A subsequent search of another vehicle he owned, prompted by his statements, led to the discovery of additional drugs and over $31,000 in cash. In total, $54,226 was seized. The individual was charged with and pled guilty to two counts of misdemeanor possession of a controlled substance.The State of Wyoming initiated a civil forfeiture action in the District Court of Carbon County, seeking to forfeit the seized currency under the Wyoming Controlled Substances Act. The State alleged the money was either proceeds from drug sales or intended to facilitate further violations of the Act. After a bench trial, the district court ordered the forfeiture of the currency, applying a preponderance of the evidence standard to determine that the money was subject to forfeiture. The individual appealed, arguing that the district court applied the wrong burden of proof and improperly considered offenses beyond those for which he was convicted.The Supreme Court of Wyoming held that the district court erred by applying the preponderance of the evidence standard rather than the statutorily required clear and convincing evidence standard to determine whether the currency was subject to forfeiture. The court reversed the forfeiture order and remanded for further proceedings under the correct standard. The court also clarified that, in forfeiture proceedings, the district court may consider violations of the Wyoming Controlled Substances Act beyond the specific offenses for which the individual was arrested or convicted. View "In the Matter of U.S. Currency Totaling $54,226.00" on Justia Law

The appellant was injured while inspecting an underground fiber optics project when he slipped and fell into a manhole, sustaining injuries to his right shoulder, left knee, and lower back. Initially, he did not report or seek compensation for a cervical spine (neck) injury. Several weeks later, he sought coverage for cervical spine surgery, claiming the work accident aggravated a preexisting condition. The Division denied coverage, concluding there was no causal relationship between the work accident and the cervical spine injury.After the denial, the appellant requested review, and the Wyoming Department of Workforce Services, Workers’ Compensation Division referred the matter to the Office of Administrative Hearings (OAH) for a contested case hearing. The OAH found that the cervical spine injury was not caused by the work accident. The appellant appealed to the District Court of Natrona County, which affirmed the OAH’s decision. The appellant then appealed to the Wyoming Supreme Court.The Supreme Court of Wyoming held that the Division erred by referring the case to the OAH instead of the Medical Commission. The Court found that the primary issue—whether the cervical spine injury was caused by the work accident—required the application of medical judgment to complex medical facts and conflicting medical diagnoses. Under Wyoming law, such “medically contested cases” must be referred to the Medical Commission. The Court reversed the lower courts’ decisions and remanded the case for further proceedings before the Medical Commission, holding that the Division was required to refer the matter to the Medical Commission because it involved a medically contested issue. View "Polzer v. State ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

Law enforcement responded to a report that a father struck his nine-year-old daughter, LC, in the head, causing her to fall and hit the floor. LC also reported verbal abuse, fear of retaliation, and concerns about inappropriate sexual behavior by her father, who is a registered sex offender. LC had a history of sexual exploitation or abuse by family members. The Wyoming Department of Family Services removed LC from the home, and the State filed a petition alleging physical and verbal abuse. The juvenile court placed LC in the Department’s custody and ordered supervised visits. The father admitted to the abuse allegations, and LC was adjudicated as a neglected child. A case plan was developed for the father, requiring him to complete a psychosexual evaluation, attend counseling, and meet other conditions. The father failed to complete the evaluation on time and did not engage in therapy, despite multiple referrals and reminders.The District Court of Goshen County initially ordered reunification as the permanency plan. After the father eventually completed the psychosexual evaluation, the Multidisciplinary Team recommended changing the plan to adoption, citing the father’s high risk of re-offending and ongoing safety concerns. The Department reported that the father had not made meaningful progress on his case plan, and LC’s therapist testified to LC’s fear of her father. Following an evidentiary hearing, the juvenile court found the Department made reasonable efforts to achieve reunification, but those efforts were unsuccessful due to the father’s lack of engagement and risk factors. The court changed the permanency plan to adoption and ceased reunification efforts.The Supreme Court of Wyoming reviewed the case. It held that the juvenile court did not abuse its discretion in changing the permanency plan from reunification to adoption, as the Department’s efforts were reasonable and reunification was not in LC’s best interest. The court also held that the juvenile court did not commit plain error by declining to adopt a concurrent permanency plan. The decision of the juvenile court was affirmed. View "L.C. v. State" on Justia Law

After their 2021 divorce, the parties agreed to joint custody of their two minor children and set a child support amount above the statutory presumptive level, with the father paying $1,700 per month. The father owns two businesses: an S-corporation and a limited liability company, both structured as pass-through entities, meaning their income is reported on his individual tax return. In 2023, the father sought to modify visitation due to changes in his work schedule, while the mother counter-petitioned to modify child support, ultimately dismissing her requests regarding custody and visitation.The District Court of Johnson County held a bench trial and denied the father’s request to modify visitation, finding no material change in circumstances. The court granted the mother’s petition to modify child support, calculating the father’s net monthly income at $40,110.66 and ordering him to pay $5,292 per month in child support. In reaching this figure, the court included both the pass-through income from the father’s businesses and the distributions reported on his individual tax return, as well as depreciation and amortization amounts from the LLC.On appeal, the Supreme Court of the State of Wyoming found that the district court abused its discretion by effectively doubling the father’s income when it included both the pass-through amounts from the businesses and the distributions already reported on his tax return. The Supreme Court held that only the amounts reported on the father’s individual tax return should be included, and that adding both sources resulted in double counting. The court affirmed the inclusion of depreciation and amortization in the income calculation. The Supreme Court reversed the district court’s child support order and remanded for further proceedings to recalculate the father’s net income and presumptive child support, instructing the lower court to obtain all relevant tax returns to ensure a complete financial picture. View "Stenson v. Stenson" on Justia Law