Justia Criminal Law Opinion Summaries

Kenneth Charles Hoffman was convicted by a jury of five counts of sexual abuse of his minor stepdaughter, SD. The incident occurred on March 10, 2023, when SD, after consuming alcohol and marijuana provided by Hoffman, was sexually assaulted by him. The next morning, SD reported the incident, and a sexual assault examination revealed seminal fluid on a tampon she had used, though the DNA was insufficient to identify its source. SD had disclosed to law enforcement that she had been sexually active with someone else about a week and a half before the incident.The District Court of Weston County reviewed the case and denied Hoffman's motion to introduce evidence of SD’s prior sexual activity, which he argued would explain the presence of the seminal fluid. The court ruled that the probative value of this evidence did not outweigh its prejudicial effect, as required by Wyoming’s rape shield statute. Consequently, Hoffman was found guilty on all charges and sentenced to 40 to 50 years in prison.The Supreme Court of Wyoming reviewed the case and upheld the lower court's decision. The court held that the district court did not abuse its discretion in excluding the evidence of SD’s prior sexual activity. The Supreme Court noted that Hoffman failed to establish a material connection between the prior sexual activity and the seminal fluid found, as the DNA evidence neither included nor excluded him. The court affirmed that the probative value of the evidence did not substantially outweigh its prejudicial effect, thus affirming Hoffman's conviction and sentence. View "Hoffman v. The State of Wyoming" on Justia Law

Danny Jarvis pled guilty to burglary in violation of Wyoming law. Before sentencing, he filed a motion to withdraw his guilty plea, which the district court denied. He was subsequently sentenced to seven to ten years in prison. Jarvis appealed, claiming the district court abused its discretion by denying his motion to withdraw his guilty plea.The district court of Weston County initially set Jarvis' bond at $10,000 cash, which was later reduced to a $10,000 personal surety bond to allow him to seek employment and attend drug treatment. Jarvis entered residential drug treatment but left to obtain medical care. At the change of plea hearing, Jarvis agreed to plead guilty to burglary in exchange for the dismissal of a felony property destruction charge. He confirmed there was no plea agreement regarding his sentence other than owing restitution. The court accepted his guilty plea after ensuring it was made knowingly and voluntarily.Jarvis later filed a pro se motion to withdraw his guilty plea, claiming he was promised a "global deal" that included the dismissal of a DUI charge in a separate case. He argued this promise was not fulfilled, rendering his plea involuntary. The district court held a hearing, allowed Jarvis to proceed pro se, and took the motion under advisement. The court ultimately denied the motion, finding Jarvis failed to show a fair and just reason for withdrawal under Wyoming Rule of Criminal Procedure 32(d).The Wyoming Supreme Court reviewed the case and affirmed the district court's decision. The court found that Jarvis did not assert his innocence, the State would not be prejudiced by withdrawal, and the delay in filing the motion was not substantial. However, the court determined Jarvis received close assistance of counsel, his plea was knowing and voluntary, and allowing withdrawal would waste judicial resources. The court concluded that the district court did not abuse its discretion in denying Jarvis' motion to withdraw his guilty plea. View "Jarvis v. The State of Wyoming" on Justia Law

Monique Huia Sullivan was convicted of voluntary manslaughter for the stabbing death of her fiancé, Andrew Moore. The couple, both sheep shearers from Australia and New Zealand, respectively, were part of a shearing crew working in Wyoming. On February 20, 2023, after a series of arguments and a difficult couple of days, Sullivan stabbed Moore once in the left side with a large kitchen knife. Sullivan was charged with second-degree murder, but the trial focused on whether she acted maliciously or in self-defense.The District Court of Lincoln County allowed John Moore, the victim's father, to testify and admitted a photograph of Moore while he was alive. Sullivan objected to both, arguing they were irrelevant and prejudicial. The court overruled her objections, and the jury found her guilty of voluntary manslaughter. She was sentenced to 12 to 17 years in prison.The Supreme Court of Wyoming reviewed the case and addressed two main issues: whether the district court abused its discretion in admitting the father's testimony and the photograph, and whether the prosecutor committed misconduct by advocating for their admission. The court found that the father's testimony about Moore's demeanor, favorite vacation spots, and the family dog was irrelevant and should not have been admitted. Similarly, the photograph was deemed irrelevant and should not have been admitted in the State's case-in-chief.However, the court concluded that the admission of this evidence was harmless error and did not materially prejudice Sullivan. The State's case was strong, with multiple witnesses and Sullivan's own admissions undermining her self-defense claim. The court also found no prosecutorial misconduct, as Sullivan failed to establish material prejudice from the prosecutor's actions. The Supreme Court of Wyoming affirmed the lower court's decision. View "Sullivan v. The State of Wyoming" on Justia Law

Clint Wayne Hammell pled guilty to felony possession of methamphetamine in May 2023 and was sentenced to four to five years of imprisonment, suspended in favor of three years of supervised probation. His probation was revoked twice in November 2023 and February 2024, with his sentence resuspended each time. After the second revocation, he was ordered to apply for and complete an adult community corrections (ACC) program, which he did at the Casper Re-Entry Center (CRC).In April 2024, the State petitioned to revoke Hammell's probation again, alleging he failed to report to a scheduled appointment with his probation agent on March 26, 2024, and did not return to the CRC, leading to his classification as an escapee. At the evidentiary hearing, his probation agent testified about his absence and subsequent arrest on March 28. The CRC case manager supervisor and a Casper Police Department officer also testified about his failure to report and his arrest.The district court found that Hammell violated his probation conditions and that his violations were willful, noting his failure to use his phone to arrange transportation back to the CRC. Consequently, the court revoked his probation and imposed the underlying sentence of four to five years with credit for time served. Hammell appealed the decision.The Supreme Court of Wyoming reviewed the case, focusing on whether the district court abused its discretion in finding Hammell's violations willful. The court upheld the district court's decision, stating that the evidence supported the finding of willfulness, as Hammell did not make efforts to contact his probation agent or return to the CRC. The court affirmed the revocation of Hammell's probation. View "Hammell v. The State of Wyoming" on Justia Law

Carolyn Aune was convicted of first-degree murder following the death of PW, a two-year-old child, due to child abuse. On March 27, 2021, PW was brought to the emergency room by her father, Moshe Williams, unresponsive and with multiple injuries, including bruises, fractures, and a transected small intestine. Despite being life-flighted to Children’s Hospital in Denver, PW succumbed to her injuries on April 4, 2021. The autopsy revealed that PW died from blunt force trauma to the abdomen, leading to sepsis and organ failure.The District Court of Park County charged both Williams and Aune with aggravated child abuse, later amended to first-degree murder after PW’s death. Aune’s trial was severed from Williams’s. During the trial, Aune testified that she witnessed Williams inflict the fatal injury on PW but did not seek medical help, believing PW was fine. The State argued that Aune either intentionally or recklessly caused PW’s injuries by failing to get prompt medical attention, which led to PW’s death.The Wyoming Supreme Court reviewed the case, focusing on whether the State presented sufficient evidence to support Aune’s conviction for felony child abuse as a requisite offense for first-degree murder and whether the prosecutor committed misconduct by misstating the law. The court found that the State provided sufficient evidence showing Aune recklessly inflicted physical injury on PW by failing to seek medical care, which led to PW’s death. The court also determined that the prosecutor did not misstate the law, as the statutes in question encompass injuries inflicted through acts of omission.The Wyoming Supreme Court affirmed Aune’s conviction, holding that the evidence supported the jury’s finding that Aune’s failure to seek medical care for PW constituted reckless infliction of physical injury, leading to PW’s death and justifying the first-degree murder conviction. View "Aune v. State" on Justia Law

Vincent Hayes was convicted of second-degree murder for shooting and killing his father, William Johnson, during an argument at their home in Casper, Wyoming. Hayes claimed he acted in self-defense, believing his father was about to shoot him. After the shooting, Hayes attempted to clean up the scene, hid the weapon, and initially fabricated a story about an intruder. He later admitted to the police that he made up the story because he thought no one would believe his self-defense claim.The District Court of Natrona County instructed the jury that it could infer malice from Hayes' use of a deadly weapon, despite his self-defense claim. Hayes did not object to this instruction at trial. The jury found Hayes guilty of second-degree murder, and he was sentenced to 50 to 75 years in prison.The Wyoming Supreme Court reviewed the case, focusing on whether the district court committed plain error by instructing the jury that it could infer malice from the use of a deadly weapon. The court held that the instruction was proper and did not violate any clear and unequivocal rule of law. The instruction was consistent with Wyoming precedent, which allows for permissive inference instructions if they are not mandatory and the state still bears the burden of proving each element of the crime beyond a reasonable doubt. The court found that the connection between the use of a deadly weapon and the inference of malice was justified by the facts of the case. Consequently, the Wyoming Supreme Court affirmed Hayes' conviction. View "Hayes v. State" on Justia Law

Jaimen Anthony Scott Aisenbrey pled guilty to two counts of possession of a controlled substance with intent to deliver as part of a plea agreement. The agreement stipulated that the State would not argue against probation if the presentence investigation (PSI) recommended it. The PSI recommended a split sentence, but at sentencing, the State requested incarceration. The district court sentenced Aisenbrey to concurrent terms of eight to ten years in prison. Aisenbrey appealed, claiming the State breached the plea agreement and that his counsel was ineffective for not objecting to the State's recommendation.The District Court of Platte County accepted Aisenbrey's guilty plea and the plea agreement terms. However, at sentencing, the State argued for incarceration despite the PSI's split sentence recommendation. Aisenbrey's counsel did not object to this recommendation. The district court imposed the prison sentence as requested by the State.The Wyoming Supreme Court reviewed the case. The court held that the State did not breach the plea agreement because a split sentence, which includes a period of confinement, is not equivalent to probation, which does not involve confinement. Therefore, the State's recommendation for incarceration did not violate the plea agreement. The court also found that Aisenbrey's counsel was not ineffective for failing to object to the State's recommendation, as there was no breach of the plea agreement to object to. The court affirmed the district court's decision. View "Aisenbrey v. State" on Justia Law

Joseph W. Russell entered a conditional guilty plea to possession of methamphetamine, reserving his right to appeal the constitutionality of a warrantless search conducted as he entered the Uinta County Courthouse. The search, performed by Deputy Dan Jensen, involved a magnetometer alerting to metal in Russell's waist area, leading to a pat-down and the discovery of a snus can containing methamphetamine. Russell was charged with felony possession of a controlled substance.The district court denied Russell's motion to suppress the evidence, finding the search reasonable under the Fourth Amendment. Russell entered a conditional guilty plea, allowing him to appeal the suppression order. He was sentenced to one to three years of imprisonment, suspended in favor of two years of supervised probation. Russell timely appealed the denial of his motion to suppress.The Wyoming Supreme Court reviewed the case, focusing on whether the search violated the Fourth Amendment. The court applied a three-part test to determine the reasonableness of the search: the nature and immediacy of the governmental concern, the efficacy of the search in addressing that concern, and the nature of the privacy interest upon which the search intrudes. The court found that courthouse security is a compelling governmental interest, the use of a magnetometer and follow-up searches are effective in addressing this concern, and the privacy interest in the snus can was minimal given the context of courthouse security.The court concluded that the search was reasonable and affirmed the district court's denial of Russell's motion to suppress. The holding emphasized that the search was justified under the special needs exception to the Fourth Amendment, balancing the government's interest in courthouse security against the minimal intrusion on Russell's privacy. View "Russell v. State" on Justia Law

Matthew Justin Olson was convicted by a jury of conspiracy to commit first-degree murder. Olson was incarcerated in the Platte County Detention Center on federal charges and had pending state charges for domestic violence against his ex-wife, SK, who was a key witness. Olson asked his cellmate, Danny Hendershott, to kill SK in exchange for a government stimulus check. Hendershott initially agreed but later reported the plot to law enforcement, leading to an undercover operation by the ATF. Olson was subsequently charged with conspiracy to commit first-degree murder.The District Court of Uinta County allowed the State to introduce evidence under Rule 404(b) of the Wyoming Rules of Evidence, indicating Olson had other serious charges pending. Olson objected, arguing this evidence was prejudicial. The court limited the State to stating Olson had four serious charges pending and SK was an important witness. Olson was found guilty and sentenced to life imprisonment. He appealed, claiming the district court erred in its pretrial ruling on the admissibility of the 404(b) evidence.The Supreme Court of Wyoming reviewed the case and found that the word "serious" was never actually introduced during the trial. The State's evidence was limited to stating Olson had pending charges without categorizing them as serious. The court held that Olson's substantial rights were not affected by the district court's pretrial ruling since the evidence presented at trial was in line with what Olson deemed appropriate. Consequently, any potential error in the pretrial ruling was deemed harmless. The Supreme Court of Wyoming affirmed Olson's conviction. View "Olson v. State" on Justia Law

Everett Bray was convicted of felony stalking his ex-wife, MS, in violation of Wyoming Statute § 6-2-506(b)(iv) and (e)(iv). After being released from prison for a prior domestic violence offense against MS, Bray went to MS’s residence in June 2022, despite being warned by the sheriff’s department not to trespass. He threatened MS and her mother, leading to his arrest and a no-contact order. In January 2023, Bray returned to MS’s property, violating the protection order, and attempted to take her dog, resulting in another arrest.The District Court of Converse County sentenced Bray to 42-84 months in prison after a jury found him guilty of felony stalking. Bray appealed, arguing that the State presented insufficient evidence to prove he had the specific intent to harass MS.The Wyoming Supreme Court reviewed the case, applying the standard that assumes the State’s evidence is true and gives the State the benefit of every favorable inference. The court found that Bray’s actions, including his threats and repeated visits to MS’s property despite warnings and a protection order, demonstrated a continuity of purpose and intent to harass. The court held that a rational jury could find Bray’s conduct showed specific intent to harass MS, affirming the conviction. View "Bray v. The State of Wyoming" on Justia Law