Justia Criminal Law Opinion Summaries

The Supreme Court reversed Defendant's conviction for two counts of forgery, holding that the district court plainly erred in accepting Defendant's guilty plea because it lacked a factual basis.Defendant was charged with two felony counts of forgery, in violation of Wyo. Stat. Ann. 6-3-602(a)(ii). Defendant pled guilty to both counts pursuant to a plea agreement. The district court found the plea voluntary, accepted the factual basis, and sentenced Defendant. The Supreme Court reversed, holding (1) the district court violated a clear and unequivocal rule of law when it accepted Defendant’s guilty plea without having a sufficient factual basis to conclude that she committed forgery under Wyo. Stat. Ann. § 6-3-602(a)(ii); and (2) Defendant suffered material prejudice when the district court sentenced her to a crime that the record did not reflect she committed. View "Delarosa v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of committing aggravated child abuse against his son, KH, and child abuse against his stepson, LT, holding that the district court did not abuse its discretion by admitting LT's out of court statement as a prior consistent statement under Wyo. R. Evid. 801(d)(1)(B).On appeal, Defendant argued that the district court erred by admitting LT's prior recorded interview statement because it constituted inadmissible hearsay and that three of the four requirements for admission of such a statement under Rule 801(d)(1)(B) were not satisfied. The Supreme Court affirmed, holding that the district court could reasonably conclude that all four requirements were satisfied and thus did not abuse its discretion in admitting LT's out of court statement. View "Hilyard v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of first-degree sexual assault, holding that there was no error in the proceedings below.After a jury trial, Defendant was found guilty of sexual assault in the first degree and sentenced to imprisonment for less than ten nor more than fifteen years. On appeal, Defendant argued, among other things, that the district court violated his Sixth Amendment right to a public trial by partially closing the courtroom in light of the COVID-19 pandemic. The Supreme Court affirmed, holding (1) the district court did not violate Defendant's right to a public trial, and Defendant waived his right to a public trial; (2) Defendant waived any appellate argument regarding the admissibility of certain evidence; and (3) Defendant failed to prove that he was prejudiced by his trial counsel's alleged errors. View "Tarpey v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of taking a controlled substance into a jail, a felony, and misdemeanor possession of a controlled substance, holding that there was no error in the convictions but remand was required for the limited purpose of correcting the written judgment and sentence.Specifically, the Supreme Court held (1) the evidence was sufficient for the jury to convict Defendant of voluntarily taking a controlled substance into a jail; (2) the evidence was sufficient for the jury to convict Defendant of knowingly possessing a controlled substance; and (3) this Court will not consider Defendant's constitutional claim because it was unpreserved and was not supported by relevant authority or cogent argument. View "Borja v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of felony domestic battery, holding that the district court did not commit prejudicial error in admitting uncharged misconduct evidence without proper notice and a Wyo. R. Evid. 404(b) hearing.After Defendant was arraigned, the district court issued an order directing the State to provide Defendant notice of any Rule 404(b) evidence it intended to use at trial. The State provided no such notice. During trial, the State told the jury in of an uncharged incident and elicited testimony from the alleged victim about the incident. The Supreme Court held (1) the State failed in its obligation to provide notice of the Wyo. R. Evid. 404(b) evidence it intended to use at the criminal trial, and the district court erred by admitting the evidence; but (2) Defendant was not prejudiced by the admission of the unnoticed Rule 404(b) evidence. View "Olson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony strangulation of a household member and misdemeanor false imprisonment, holding that the district court did not err or abuse its discretion in the proceedings below.On appeal, the Supreme Court held that the district court (1) did not err by concluding that the affidavit in support of the search warrant to search Defendant's cellular phones, his place of employment, his work truck, and his person for certain documents, including journals, established probable cause to search and seize Defendant's journals and in thus denying Defendant's motion to suppress; and (2) did not abuse its discretion at sentencing by considering conduct for which Defendant was acquitted. View "Kreusel v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's most recent motion to correct an illegal sentence on the ground that he was entitled to credit against both of his consecutive sentences, holding that the district court did not err.After the district court denied Defendant's first two motions to correct an illegal sentence pursuant to Wyo. R. Crim. P. 35(a), Defendant filed a third motion pursuant to Rule 35(a) asking the district court to award him credit for 426 days of presentence confinement. The district court denied the request, concluding that the doctrine of res judicata had preclusive effect in this case. The Supreme Court affirmed, holding (1) while Defendant's appeal could be barred by res judicata this Court exercises its discretion to consider the merits of the appeal; and (2) Defendant was entitled to receive 426 days of presentence confinement, and because Defendant received that credit against his total term of imprisonment, his sentence was legal. View "Cruzen v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for second-degree sexual abuse of a minor, holding that there was sufficient evidence to support the conviction.After a jury trial, Defendant was convicted of second-degree sexual abuse of a minor under Wyo. Stat. Ann. 6-2-315(a)(ii) and third-degree sexual abuse of a minor under Wyo. Stat. Ann. 6-2-316(a)(iv). On appeal, Defendant challenged the sufficiency of the evidence supporting only his conviction for second-degree sexual abuse of a minor, arguing there was insufficient evidence of intent to support the conviction. The Supreme Court affirmed, holding that, under the facts and circumstances of this case, the evidence was sufficient to support the conviction for second-degree sexual abuse of a minor. View "Morris v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court reducing Joshua Anderle's sentence for sexual abuse of a minor by two years following his completion of the Youthful Offender Transition Program, holding that the district court did not abuse its discretion by reducing Anderle's sentence by two years in recognition of his successful completion of the program.Anderle entered an Alford plea to second-degree sexual abuse of a minor. The district court sentenced him to eight to twelve years' imprisonment and recommended that the Wyoming Department of Corrections treat Anderle as a youthful offender under Wyo. Stat. Ann. 7-13-1001 et seq. After Anderle successfully completed the program the court held a sentence reduction hearing and reduced Anderle's sentence by two years. The Supreme Court affirmed, holding that the district court reasonably declined to reduce Anderle's sentence to probation. View "Anderle v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of two counts of aggravated assault for attempting to cause harm to others after he led law enforcement on a high-speed chase and nearly collided with with a patrol car occupied by a law enforcement officer, holding that the record was unclear as to the state of Defendant's second aggravated assault conviction.At issue on appeal was whether the district court abused its discretion when it instructed the jury that attempted aggravated assault under Wyo. Stat. Ann. 6-2-502(a)(i) could be committed knowingly. The Supreme Court reversed Defendant's convictions, holding (1) the legislature did not intend to create a general intent attempt crime when it defined attempted aggravated assault; and (2) a jury instruction and verdict form did not provide the "jury a correct and legally sufficient basis" upon which to convict Defendant. The Court remanded the case for clarification and resentencing, if necessary. View "Schuerman v. State" on Justia Law