Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of one count of third-degree sexual abuse of a minor, holding that there was sufficient evidence to support the conviction.Defendant was convicted of sexually assaulting his niece, DT. On appeal, Defendant argued that DT's testimony during trial lacked credibility and could not support his conviction and that, alternatively, the State was only able to establish the first element of the offense through leading questions. The Supreme Court rejected Defendant's arguments and affirmed, holding that the evidence was sufficient to support the jury's verdict. View "Deephouse v. State" on Justia Law

The Supreme Court reversed the judgment of the district court granting Defendant's petition for relief from the requirement that Defendant register as a sex offender in Wyoming pursuant to the Wyoming Sex Offender Registration Act, holding that the district court's rulings concerning Wyoming Division of Criminal Investigation's (DCI) authority under the Act were erroneous.In 1999, Defendant pleaded guilty to misdemeanor sexual battery in Georgia. In 2019, a federal agency informed DCI that that it had intercepted a firearm suppressor addressed to Defendant, who was living in Casper, Wyoming. After discovering his Georgia conviction, DCI directed Defendant to register as a sex offender in the state. Defendant filed a petition seeking relief from the requirement. The district court granted DCI summary judgment. The Supreme Court reversed, holding (1) because the Act's requirement to register as a sex offender is premised on a conviction, DCI may not rely on dismissed charges to determine an individual's registration requirements; and (2) DCI may not require someone to register before it knows that he was convicted of a registrable offense. View "Minter v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of immodest, immoral, and indecent liberties with a minor, third-degree sexual assault, and first-degree sexual abuse of a minor, holding that Defendant was not entitled to relief on his four allegations of error.Specifically, the Supreme Court held (1) the evidence was sufficient to support Defendant's conviction of third-degree sexual assault; (2) the trial court erred in admitting certain evidence, but Defendant was not prejudiced by the error; (3) the prosecutor made a statement during the State's closing argument regarding the victim's veracity, but Defendant was not prejudiced by the error; and (4) there was no reasonable possibility that cumulative effect of the errors at trial deprived Defendant of a fair trial. View "King v. State" on Justia Law

The Supreme Court reversed Defendant's conviction for misdemeanor interference with a peace officer stemming from his act of resisting when police officers entered his home without a warrant to arrest him for a misdemeanor crime, holding that, under the circumstances of this case, Defendant's conviction could not stand.On appeal, Defendant argued that the officers' warrantless entry into his home was unlawful, and therefore, the trial court erred in denying his motion to suppress. The Supreme Court reversed, holding (1) the officers in this case were not "engaged in the lawful performance" of their official duties when they entered Defendant's home without a warrant, as required to convict him under Wyo. Stat. Ann. 6-5-204(a); and (2) because the officers' warrantless entry into Defendant's home was per se unreasonable, the warrantless entry into Defendant's home to execute a warrantless arrest violated Defendant's rights under the Fourth Amendment. View "Woods v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of stalking his ex-wife, holding that Defendant was not denied his right to a speedy trial and that the trial court did not commit prejudicial error in instructing the jury.After a jury trial, Defendant was found guilty of one count of felony stalking and sentenced to four to six years in prison. The Supreme Court affirmed, holding (1) Defendant was not denied his right to a speedy trial under either Wyo. R. Crim. P. 48 or the Sixth Amendment to the United States Constitution; and (2) the district court abused its discretion by giving instruction number fourteen because it described stalking as a general intent crime when it, in fact, is a specific intent crime, but Appellant did not meet his burden to demonstrate prejudice. View "Person v. State" on Justia Law

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