Justia Criminal Law Opinion Summaries

Articles Posted in Wyoming Supreme Court
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The Supreme Court affirmed Defendant's convictions of one count of aiding and abetting attempted second-degree murder, one count of reckless endangering, and one count of misdemeanor possession of methamphetamine, holding that the district court did not err in denying Defendant's request for a jury instruction on the lesser-included offense of accessory to attempted voluntary manslaughter.Defendant was a passenger in her co-defendant's vehicle when the co-defendant led law enforcement on a high speed chase. Defendant was convicted for her part in the crimes committed. The Supreme Court affirmed Defendant's convictions but remanded for correction of the district court's written sentencing order, holding (1) the district court did not err when it declined to give Defendant's proposed jury instruction on the lesser-included offense of accessory to attempted voluntary manslaughter; and (2) the court's written sentencing order deviated from its oral pronouncement. View "Jacobs v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of one count of felony strangulation of a household member and one count of misdemeanor domestic battery, holding that there was no error.On appeal, Defendant argued that the district court violated his due process rights when it refused to allow him to plead guilty to domestic battery and by refusing to accept his guilty plea. The Supreme Court affirmed, holding (1) Defendant failed to establish that he had a protected due process interest in changing his plea to guilty; and (2) the district court did not abuse its discretion when it denied Defendant's request to change his pleas. View "Miller v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of third-degree sexual assault and sentencing him to a sentence of five to eight years in prison, holding that there was no error in the proceedings below.Defendant entered an Alford plea to third-degree sexual assault. On appeal, Defendant argued two arguments relating to his competency at sentencing. The Supreme Court affirmed, holding (1) the district court did not err in imposing Defendant's sentence without first making an oral finding that Defendant was competent to proceed; and (2) the district court did not err by making a written finding that Defendant was competent to proceed with sentencing rather than sua sponte suspending the sentencing hearing and ordering him to undergo a third competency evaluation. View "Merlak v. State" on Justia Law

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The Supreme Court affirmed Defendant's convictions for attempted second-degree murder, felony property destruction, and other offenses, holding that the district court did not err when it denied Defendant's motion for judgment of acquittal.On appeal, Defendant argued that there was insufficient evidence to support his convictions for property destruction and felony possession of methamphetamine. The Supreme Court disagreed, holding (1) the district court did not err in denying Defendant's motion for a judgment of acquittal on the two property destruction counts because Defendant's conduct provided the required mens rea to impose criminal liability; and (2) the evidence was sufficient for the jury to determine beyond a reasonable doubt that Defendant was guilty of felony possession of methamphetamine. View "Childers v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of strangulation of a household member, holding that there was no error in the district court's evidentiary rulings.On appeal, Defendant argued, among other things, that the district court abused its discretion by admitting recorded phone calls into evidence. As to this evidence, the district court made only a cursory Wyo. R. Evid. 404(b) ruling and did not review any of the Gleason factors. The Supreme Court affirmed, holding (1) Defendant was not prejudiced by the district court's decision to admit evidence that Defendant violated a no-contact order when he called the victim from jail; and (2) the district court did not err when it admitted the victim's hearsay statement recorded on the responding officer's body cam as an excited utterance. View "Jackson v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder, holding that the opinion testimony of a forensic pathologist did not materially prejudice Defendant's defense.On appeal, Defendant argued that the district court abused its discretion by admitting improper Wyo. R. Evid. 404(b) of a previous 911 call and surrounding events from 2011 and that the prosecutor's question eliciting the opinion of the forensic pathologist that the cause of death was homicide was plain error. The Supreme Court disagreed, holding (1) the district court did not abuse its discretion when it admitting evidence surrounding the 911 call; and (2) there was no reasonable probability that, absent the prosecutor's question to the forensic pathologist on the cause of death, the verdict would have been more favorable to Defendant. View "Klingbeil v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of three counts of third-degree sexual abuse of a minor between the ages of thirteen and fifteen years, holding that the district court did not improperly instruct the jury on Defendant's theory of defense that he reasonably believed the victim was at least sixteen years old.Specifically at issue was whether the district court erred by defining "reasonable belief" for the jury and by refusing to instruct the jury on the details of Defendant's theory of defense. The Supreme Court affirmed, holding (1) even if the district court erred by providing the definition of "reasonable belief" to the jury, Defendant failed to explain how he was prejudiced by the instruction; and (2) the district court did not err by refusing to provide additional details of Defendant's theory of defense. View "Bernal-Molina 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 aggravated assault and battery, holding that the district court abused its discretion in allowing the hearsay testimony of two law enforcement officers at trial, but the error was not prejudicial.Specifically, the Supreme Court held (1) the officers' testimony repeating the complaining witness's out-of-court statements was not admissible under Wyo. R. Evid. 801(d)(1)(B); (2) the district court abused its discretion in allowing the officers to testify to the complaining witness's out-of-court statements to explain their investigation; and (3) there was no reasonable probability that the verdict would have been more favorable to Defendant had the improper hearsay evidence not been admitted. View "Thompson v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court finding Defendant guilty of four counts of sexual abuse of a minor, holding that Defendant knowingly and intelligently waived his Miranda rights and that Defendant did not receive ineffective assistance of counsel.At a hospital, Defendant made incriminating statements to law enforcement officers that he had sexually abused his daughter. Defendant filed a motion to suppress his confessions on the grounds that he was lacking contact with reality when he confessed. The district court denied the motion to suppress, finding that Defendant waived his Miranda rights voluntarily, knowingly, and intelligently. Thereafter, Defendant was convicted. The Supreme Court affirmed, holding (1) Defendant voluntarily waived his Miranda rights; and (2) Defendant's trial counsel provided effective assistance at each phase of Defendant's prosecution. View "Jendresen v. State" on Justia Law

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The Supreme Court affirmed the district court's denial of Defendant's motion to correct an illegal sentence and the issuance of a nunc pro tunc judgment conforming Defendant's written sentence to the court's oral pronouncement at his sentencing hearing, holding that there was no error in Defendant's sentence.Defendant was convicted of conspiracy to commit first degree murder and sentenced to life in prison. Defendant later filed a motion to correct an illegal sentence, claiming that his written judgment and sentence was illegal under Hartley v. State, 460 P.3d 716 (Wyo. 2020). The district court denied the motion without a hearing and then issued a nunc pro tune judgment correcting the written sentence to conform it to the oral pronouncement. The Supreme Court affirmed, holding (1) the district court properly corrected Defendant's written sentence without a hearing; and (2) the sentence complied with Wyoming law. View "Brown v. State" on Justia Law