Justia Criminal Law Opinion Summaries

Articles Posted in Wyoming Supreme Court
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The Supreme Court affirmed Defendant's aggregate sentence that left him eligible for parole after serving thirty-five years, holding that Defendant failed to show a constitutional violation or an abuse of discretion in the district court's sentencing decision. Defendant was convicted of one count of first-degree murder and twelve counts of aggravated assault and battery for crimes he committed at age sixteen. The district court sentenced Defendant to an aggregate prison term that left him eligible for parole after fifty-two years. The Supreme Court reversed the sentence and remanded for resentencing, holding that the sentence violated the Eighth Amendment because it was a de facto life without parole sentence. On remand, the district court imposed an aggregate sentence that left Defendant eligible for parole after serving thirty-five years. The Supreme Court affirmed, holding that Defendant's sentence did not violate the Eighth Amendment and that the district court did not abuse its discretion in sentencing Defendant. View "Sam v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of sexual assault in the third degree and intentional abuse of a vulnerable adult, holding that there was no error in the proceedings below. On appeal, Defendant argued that the district court erred when it admitted hearsay testimony of five witnesses and a video recording of the victim's Children Advocacy Project (CAP). Defendant also argued that the evidence was insufficient for the jury to convict him of the offenses. The Supreme Court affirmed, holding (1) neither the admission of the challenged testimony nor the CAP interview video violated a clear and unequivocal rule of law in a clear and obvious way, and in any event, Defendant failed to meet his burden of proving that he was materially prejudiced by admission of the evidence; and (2) the evidence was sufficient for the jury to convict Defendant of both sexual assault in the third degree and intentional abuse of a vulnerable adult. View "Brown v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Defendant's motions to withdraw his no contest plea to driving under the influence of alcohol, holding that Defendant's no contest plea was not knowing or voluntary, and therefore, the district court abused its discretion in denying Defendant's motions to withdraw his plea. On appeal, Defendant argued that his plea was not knowing or voluntary because the totality of the circumstances showed he did not fully understand the amended charge, the plea agreement, or the consequences of his plea. Further, Defendant claimed that he had insufficient time to speak with his attorney to discuss these matters prior to pleading guilty. The Supreme Court agreed, holding (1) under the specific circumstances of this case, Defendant's plea was not knowing or voluntary; and (2) the district court abused its discretion in not allowing Defendant to withdraw his no contest plea. View "Steffey v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of strangulation of a household member, holding that the district court did not err in admitting certain testimony and that the evidence was sufficient to establish the elements of strangulation. Defendant was convicted of strangulation and domestic battery for an incident in which Defendant's wife was found badly beaten. Defendant appealed only his strangulation conviction, arguing, among other things, that the district court erred in admitting the testimony of his wife's treatment physician for the truth of the matter asserted after ruling that the testimony would be admitted only for impeachment. The Supreme Court affirmed, holding (1) assuming that the district court's statement limiting the physician's testimony was in fact a ruling, Defendant failed to establish that the admission was prejudicial; and (2) the evidence was sufficient to support the jury's finding that Defendant caused bodily injury by impeding his wife's normal circulation of blood. View "Gonzalez-Chavarria v. State" on Justia Law

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The Supreme Court reversed Defendant's conviction of sexual assault in the first degree, holding that cumulative error resulting from prosecutorial misconduct deprived Defendant of a fair trial. On appeal, Defendant argued that the prosecutors committed numerous instances of misconduct during the state's case-in-chief and during the State's closing and rebuttal arguments. The Supreme Court remanded the case for a new trial, holding (1) the prosecutor violated the district court's Wyo. R. Evid. 404(b) order; (2) both prosecutors engaged in improper victim impact argument unrelated to credibility; (3) the prosecutor repeatedly argued facts that were not in evidence; (4) the prosecutor intentionally used inflammatory language in closing argument; and (5) cumulative error deprived Defendant of a fair trial. View "Bogard 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 child endangerment and one count of possession of a controlled substance, holding that the district court did not violate Defendant's Fifth Amendment right to remain silent by admitting testimony regarding Defendant's contamination of a compelled urine sample. On appeal, Defendant argued that evidence of her contamination of the urine sample was admitted in violation of her right to remain silence because the contamination communicated her guilty knowledge or consciousness of guilt. The State raised the additional question of whether Defendant waived her Fifth Amendment claim when she failed to raise it in the district court. The Supreme Court affirmed, holding (1) Defendant had good cause for failing to raise her Fifth Amendment claim before trial so the claim was not waived; and (2) Defendant's decision to contaminate her sample was neither a communicative act nor an act compelled by the State, and therefore, evidence of Defendant's actions was not protected by the Fifth Amendment, and there was no plain error in the admission of the evidence. View "Herrera v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court granting summary judgment in favor of the University of Wyoming (UW) and dismissing Plaintiff's declaratory judgment action, arguing that the district court abused its discretion in concluding that this declaratory judgment action challenging the legality of a UW regulation barring firearms on the UW campus served a useful purpose. Plaintiff was cited for misdemeanor criminal trespass after he refused to either relinquish his handgun, which he brought to a UW facility. Plaintiff pleaded not guilty in circuit court, obtained a stay of the criminal proceedings, and filed an action for declaratory judgment in district court, arguing that the regulation violated his constitutional right to bear arms. The district court granted summary judgment for UW. The Supreme Court reversed with instructions so that the matter may proceed in the circuit court, holding (1) Defendant had standing the challenge the legality of the regulation because of the pending criminal charge against him; and (2) the district court abused its discretion in concluding that this declaratory judgment action served a useful purpose. View "Williams v. State ex rel., University of Wyoming Board of Trustees" on Justia Law

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The Supreme Court affirmed the district court's entry of a restitution order following an unconditional no contest plea to one count of exploitation of a vulnerable adult, holding that the district court did not act contrary to law in awarding restitution. Defendant pled no contest to one count of exploitation of a vulnerable adult. The district court sentenced Defendant to not less than eight nor more than ten years of incarceration, suspended in favor of ten years of probation. The court then awarded restitution of $532,890.80. Defendant appealed, challenging the award of restitution. The Supreme Court affirmed, holding that the district court reasonably awarded restitution in this matter. View "Freeman v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree sexual abuse of a minor, holding that Defendant was not entitled to relief on any of his allegations of error. Defendant was charged with three counts of first-degree sexual abuse of a minor. Defendant was convicted on counts I and III and acquitted on count II. Defendant appealed his conviction on count I, claiming, among other things, that the trial court committed reversible error because the jury instructions contained identical elements for counts I and II with nothing to differentiate the counts and because the verdict form also failed to distinguish between the two counts. The Supreme Court reversed, holding (1) Defendant waived review of his challenge regarding the description of counts I and II under the invited error doctrine; (2) the evidence was sufficient to convict Defendant on count I; and (3) Defendant's counsel was not ineffective. View "Jackson v. State" on Justia Law

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The Supreme Court affirmed the decision of the district court granting the State's motion to vacate an order granting Appellant relief from the requirement to register as a sex offender and reviving Appellant's registration requirement, holding that the district court did not abuse its discretion when it granted the State's motion for relief. Appellant petitioned the district court to terminate his duty to register as a sex offender, claiming that he met the statutory requirements under Wyo. Stat. Ann. 7-19-304(a)(i). The district court granted the petition. Thereafter, the State filed a Wyo. R. Crim. P. 60 motion alleging that Appellant was not eligible for relief from the duty to register. The district court granted the motion, finding that Appellant was not statutorily eligible for termination because he was convicted of incest as an adult and not adjudicated as a delinquent. The Supreme Court affirmed, holding that the district court's order granting the State's motion to vacate the judgment relieving Defendant from the sex offender reporting requirement was an appropriate exercise of judicial discretion. View "Gunsch v. State" on Justia Law