Justia Criminal Law Opinion Summaries

Articles Posted in Wyoming Supreme Court
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The Supreme Court affirmed the judgment of the district court convicting Defendant of intimidating and influencing a witness in violation of Wyo. Stat. Ann. 6-5-305(a), holding that Defendant did not show that the prosecutor's comments in rebuttal closing argument or the district court's failure to instruct the jury on voluntariness constituted plain error. Specifically, the Court held (1) the prosecutor did not commit plain error during rebuttal closing argument by improperly shifting the burden of proof to Defendant or stating facts not in evidence; and (2) the district court did not plainly err in failing to instruct the jury that it had to find Defendant acted voluntarily. View "Black v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of misdemeanor interference with a peace officer, holding that Defendant's actions were sufficient to constitute interference with a peace officer and that the circuit court did not err in refusing to give Defendant's proposed jury instruction. Specifically, the Supreme Court held (1) the jury was presented with sufficient evidence to find Defendant guilty of misdemeanor interference with a peace officer; and (2) the circuit court did not err in rejecting Defendant's proposed jury instruction concerning the type of verbal conduct that may constitute interference with a peace officer. View "Garza v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of two counts of sexual intrusion on a victim under Wyo. Stat. Ann. 6-2-314(a)(i), holding that the district court did not err when it admitted testimony under Wyo. R. Evid. 404(b) and 801(d)(1)(B) and did not violate Defendant's rights under the Confrontation Clause when it allowed the State to amend the felony information after the State had presented its witnesses. Specifically, the Supreme Court held (1) the district court did not abuse its discretion in admitting evidence of other acts under Rule 404(b) or in allowing the victim's prior consistent statements under Rule 801(d)(1)(B); and (2) the amendment to the felony information without a continuance did not deny Defendant his right to effectively cross-examine the witnesses or prejudice his defense. View "LaJeunesse v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of felony possession of marijuana, holding that the State's trial evidence was sufficient to establish that Defendant possessed the marijuana. Defendant was convicted of violating Wyo. Stat. Ann. 35-7-1031(c)(iii), which makes it a felony for a person to knowingly or intentionally have in his possession more than three ounces of marijuana in plant form. On appeal, Defendant argued that the State did not prove he exercised dominion and control over the marijuana. The Supreme Court affirmed, holding that the trial evidence was clearly sufficient to support the jury's conclusion that Defendant constructively possessed more than three ounces of marijuana. View "Huckins v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court convicting Defendant of two counts of possession with intent to deliver a controlled substance and one count of interference with a peace officer, holding that Defendant's trial counsel provided ineffective assistance by failing to challenge the extension of Defendant's traffic stop. The traffic stop in this case led to the discovery of drugs and drug paraphernalia in Defendant's vehicle. Defendant filed a motion to suppress, arguing that the initial stop was not supported by reasonable suspicion. The district court denied the motion. On appeal, Defendant argued, among other things, that his trial counsel provided ineffective assistance by failing to challenge the duration of the traffic stop in his motion to suppress. The Supreme Court reversed and remanded the case, holding (1) Wyo. R. Crim. P. 12(b) precluded plain error review of the issues not raised in Defendant's motion to suppress evidence; and (2) Defendant showed a reasonable probability that, but for counsel's failure to challenge the duration of the stop and the actions of law enforcement officers during the stop, the outcome of the trial would have been different. View "Mills v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of three counts of second-degree sexual assault, holding that the district court did not plainly err in failing to instruct the jury that it had to fine beyond a reasonable doubt that Defendant acted voluntarily. On appeal, Defendant argued that because second-degree sexual assault is a general intent crime, it required a voluntary act, and therefore, the district court erred in failing to instruct the jury on the mens rea element of second-degree sexual assault. The Supreme Court affirmed, holding that no instruction on voluntariness was required where Defendant did not show she was prejudiced by any alleged failure to provide a voluntariness instruction to the jury and Defendant did not present any evidence suggesting her actions were not voluntary. View "Wyant v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of possession with intent to deliver marijuana, holding that the State's evidence at trial was sufficient to prove Defendant constructively possessed the marijuana. A jury found Defendant guilty of possession with intent to deliver marijuana in violation of Wyo. Stat. Ann. 35-7-1031(a)(ii). The district court sentenced Defendant to a term of incarceration of four to nine years, sentence suspended. On appeal, Defendant argued that the State failed to prove he possessed the marijuana. The Supreme Court affirmed, holding that the State's evidence was clearly sufficient to establish that Defendant had constructive possession of the marijuana. View "Pyles v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of two counts of operating a vehicle while under the influence of alcohol pursuant to Wyo. Stat. Ann. 31-5-233(b)(i) and (b)(iii), holding that the district court did not abuse its discretion when it admitted evidence of Defendant's blood alcohol concentration (BAC) and that Defendant was not denied due process or an opportunity to conduct an effective cross-examination at trial. On appeal, Defendant argued that the trial court erred by admitting his BAC because the State failed to establish that his blood analysis was performed according to methods approved by the Wyoming Department of Health and that the error was prejudicial. The Supreme Court affirmed, holding (1) the district court should have compelled production of a linearity study related to the calibrator for Defendant's blood samples test, but the error was harmless; and (2) Defendant was not denied his constitutional right to due process or an opportunity to confront the State's witnesses. View "Hardman v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree sexual abuse of a minor, holding that Defendant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48. Defendant was charged with one count of first-degree sexual abuse of a minor. On April 9, 2018, the district court arraigned Defendant, starting the 180-day speedy trial clock. Defendant's trial, however, was not held within 180 days of his arraignment. Instead, Defendant's trial commenced on October 15, 2018, 190 days later. At issue was whether the district court properly continued the trial beyond the 180-day mandate of Rule 48(b). The Supreme Court affirmed, holding (1) the district court properly granted a continuance under Wyo. R. Crim. P. 48(b)(4)(A) even though Defendant did not agree to a continuance and the motion was not supported by a written affidavit; and (2) therefore, the ten-day continuance did not count toward the 180-day limit, and Defendant was not denied his right to a speedy trial. View "Flores-Gomez v. State" on Justia Law

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The Supreme Court affirmed Defendant's sentence imposed in connection with his conviction of domestic battery and failure to register as a sex offender, holding that the district court gave Defendant adequate credit for his presentence confinement. Pursuant to a plea agreement, Defendant pleaded guilty to domestic battery and failure to register as a sex offender. The court sentenced Defendant to a prison term of two to three years for the failure to register and a term of 180 days for the domestic battery, to run concurrently with each other and the sentence Defendant was already serving. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in denying Defendant's requested credit; and (2) because Defendant was not promised credit in addition to that to which he was entitled by law, he was not impermissibly induced to plead guilty, and his protected interest in the credit was not affected. View "Petersen v. State" on Justia Law