Justia Criminal Law Opinion Summaries

Articles Posted in Wyoming Supreme Court
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The Supreme Court affirmed the order of the district court adjudicating JP delinquent and the corresponding order of disposition, holding that Defendant did not receive ineffective assistance of counsel when his attorney failed timely to demand a jury trial.The State filed a delinquency petition alleging that seventeen-year-old JP inflicted sexual intrusion on a thirteen-year-old girl. After a hearing, the juvenile court found that JP committed a delinquent act and sentenced him to one year of juvenile probation. On appeal, JP argued that he was prejudiced by his counsel's failure to timely demand a jury trial. The Supreme Court affirmed, holding that JP failed to show the outcome of his case would have been different if it had been tried to a jury. View "JP v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of one count of sexual assault in the third degree, holding that the district court did not err when it allowed the State to amend the felony information before submitting the case to the jury.The State charged Defendant by felony information with three identical counts of sexual assault in the third degree. Before trial, the district court asked the State to differentiate the charges, but the court did not act immediately on the request. After the State's presentation of evidence Defendant moved for a judgment of acquittal on the ground that the felony information did not differentiate between the counts. The district court denied the motion and granted the State's motion to amend the felony information. After Defendant was convicted he appealed. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it allowed the State to amend the felony information during trial; and (2) Defendant's substantial rights were not prejudiced by the amendment. View "Roberts v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court sentencing Defendant to the maximum term of fifteen to twenty years for aggravated vehicular homicide and a concurrent six months for driving under the influence, holding that the district court plainly erred when it considered Defendant's silence and community expectations in sentencing her.On appeal, Defendant argued that her constitutional right to a fair sentence was violated when the district court "emphasized, and likely punished, her decision to exercise her constitutional rights at the time of her arrest" and when the court expressed that "the severity of the sentence depended upon the county in which it presided over her." The Supreme Court agreed and remanded the case for a new sentencing hearing, holding that the district court erroneously incorporated constitutionally-prohibited factors into its sentencing decision and that the application of those constitutionally-prohibited factors in sentencing undermined the fairness and integrity of the judicial proceedings. View "Jewkes v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court modifying Father's child support order and ordering Father to pay $4,596.71 in child support arrears, holding that the district court did not abuse its discretion.In 2012, the district court entered an order establishing custody and support for Father's and Mother's children. The Department of Family Services, Child Support Enforcement Division later filed a petition to modify Father's child support order. Father answered, requesting that he be relieved of his child support arrears. The district court denied Father's request for relief, modified the child support order, and ordered Father to pay child support arrears. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it denied Father's request for relief from the 2012 child support order. View "Carroll v. State ex rel. Department of Family Services" on Justia Law

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The Supreme Court affirmed Defendant's conviction of attempted first-degree arson, entered after a jury trial, holding that the evidence was sufficient to support the conviction and that the district court did not commit plain error by allowing a police officer to testify that gasoline is an accelerant.On appeal, Defendant argued that the State presented insufficient evidence to support his attempted first-degree arson conviction and that a police officer improperly opined as an expert that a liquid he identified as gasoline found in Defendant's home was an accelerant despite not being qualified to testify as an expert under Wyo. R. Evid. 702. The Supreme Court affirmed, holding (1) sufficient evidence supported the conviction; and (2) as to his remaining assignment of error, Defendant failed to satisfy the second prong of plain error review. View "Esquibel v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction for misdemeanor stalking and strangulation of a household member, entered upon his guilty plea, holding that Defendant gave a sufficient factual basis to support his guilty plea.At the change of plea hearing when he was asked about the factual basis for the counts, Defendant did not give detailed answers, instead providing "yes" answers to the questions of both counsel and the court. After Defendant's attorney questioned him, the trial court found there was a factual basis for both counts and accepted Defendant's plea. The Supreme Court affirmed, holding that the district court did not violate a clear and unequivocal rule of law when it accepted his guilty plea. View "Beeson v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of felony possession of marijuana, entered following Defendant's conditional guilty plea, holding that the initial traffic stop of Defendant in this case comported with the requirements of the Fourth Amendment to the United States Constitution.In denying Defendant's motion to suppress, the trial court concluded that the initial traffic stop was justified as a drug trafficking investigation. Defendant appealed, arguing that the district court erred in concluding the officer had reasonable suspicion to stop Defendant based on the collective knowledge doctrine. The Supreme Court affirmed, holding that the initial stop was legally justified under the Fourth Amendment, and therefore, the district court did not err in denying Defendant's motion to suppress. View "Guandong v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of sexual abuse of a minor in the second degree, holding that Defendant failed to establish that the district court committed plain error by allowing certain testimony.On appeal, Defendant argued that plain error occurred during trial when the district court allowed State witnesses to vouch for the credibility of other State witnesses and/or to offer opinions as to Defendant's guilt. The Supreme Court disagreed and affirmed, holding (1) the State's witnesses did not vouch for the credibility of other witnesses or offer opinions as to Defendant's guilt; and (2) in the absence of any error, the cumulative error doctrine did not apply. View "Ingersoll v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence, holding that there was no error.Defendant was convicted of three counts of first-degree sexual assault, one count of kidnapping, and one count of aggravated assault and battery. The Supreme Court affirmed on direct appeal. Defendant later filed his motion to correct an illegal sentence, asserting that his sentence violated constitutional prohibitions against double jeopardy. The district court denied relief, determining that Defendant's claims were barred by res judicata and failed on the merits. The Supreme Court affirmed, holding that Defendant's motion to correct an illegal sentence was barred by res judicata. View "Harrell v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence obtained after law enforcement entered her home without a warrant or consent, holding that the district court erred.Defendant entered a conditional plea of guilty to felony driving under the influence. On appeal, Defendant challenged the district court's denial of her motion to suppress, arguing that the record did not support a finding that her husband consented to a law enforcement officer's entry into their home. The Supreme Court reversed and remanded the case, holding (1) the district court erred in concluding that the officer had implied consent to enter the home; and (2) therefore, the officer violated the Fourth Amendment to the United States Constitution. View "Hawken v. State" on Justia Law