Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgments of the district courts denying Appellants' separate motions to suppress, holding that the Wyoming Constitution does not require that an exterior canine sniff of a vehicle be supported by probable cause.Appellants in these cases were both subjected to an extended investigative detention, and both Appellants were arrested after a canine sniff of their vehicles. On appeal, Appellants argued that the canine sniffs had to be supported by probable cause under Wyo. Const. art. I, 4. The Supreme Court disagreed, holding (1) the Wyoming Constitution does not require probable cause for an exterior canine sniff of a vehicle; and (2) Appellants were not entitled to relief on their remaining allegations of error. View "Tarzia v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction on one count each of stalking in violation of a protective order and criminal entry, holding that the prosecutor did not make improper comments in closing argument and that the district court did not plainly err in defining "spying distance."On appeal, Defendant argued that the prosecutor committed prosecutorial misconduct in closing by commenting on Defendant's silence and that the district court erred in allowing the State's witness to discuss "spying distance," a term not referenced in the stalking statute. The Supreme Court affirmed but remanded the case for correction of the date in the judgment and sentence, holding (1) Defendant failed to establish plain error as to his first two arguments on appeal; and (2) the district court did not plainly err when it allowed the State's witness to testify regarding his understanding of the definition of "spying distance." View "Hembree v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion for sentence reduction, holding that the district court did not abuse its discretion in denying the motion.Appellant pled guilty to aggravated assault and battery and was sentenced to a period of incarceration for not less than four years nor more than eight years. Appellant later filed a motion for a sentence reduction requesting that the district court reduce his sentence to not less than three years nor more than six years based on his commendable conduct while incarcerated. The district court denied the motion. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it denied Defendant's motion for sentence reduction. View "Harper v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's claims against Defendant, the mayor of Green River, as time-barred, barred under 42 U.S.C. 1983, and barred by the doctrine of collateral estoppel, holding that the district court did not err.In his complaint, Plaintiff alleged that Defendant violated his oath of office during Plaintiff's underlying criminal matter by declining to order an investigation into a witness who recanted prior statements she made to law enforcement. The district court dismissed the complaint. The Supreme Court affirmed, holding (1) the district court did not err when it determined that Plaintiff's claims were barred by the Wyoming Governmental Claims Act and 42 U.S.C. 1983; (2) Plaintiff failed to present cogent argument on his collateral estoppel argument; and (3) therefore, the district court properly granted Defendant's motion to dismiss. View "Mitchell v. Rust" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony possession of methamphetamine, holding that the district court did not err in denying Defendant's multiple motions to suppress challenging the validity of the warrant and supporting affidavit police obtained to search his residence.On appeal, Defendant argued that Officer Andy Lucas of the Gillette Police Department knowingly, or with reckless disregard, omitted facts from the search warrant affidavit and that the warrant was not sufficiently particular to remain valid under the Fourth Amendment. The Supreme Court disagreed, holding (1) the district court did not clearly err in finding Officer Lucas had not recklessly omitted information from the affidavit; and (2) the search warrant contained sufficient information to allow Officer Lucas to identify the place to be searched with reasonable effort. View "Herdt v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained after law enforcement forced open a lacked box during an inventory search of Defendant's vehicle, holding that the district court did not err.During an inventory search of Defendant's vehicle, the police forced open a locked box and discovered suspected illegal drugs. The State charged Defendant with felony possession of methamphetamine and misdemeanor possession of heroin. Defendant moved to suppress the evidence obtained from the box, arguing that opening the box exceeded the scope of a permissible inventory search in violation of the Wyoming Highway Patrol's (WHP) inventory policy, thus violating his Fourth Amendment rights. The district court denied the motion, after which Defendant entered a conditional plea of guilty to felony possession of methamphetamine. The Supreme Court affirmed, holding that Defendant's argument that the inventory search violated WHP policy was unavailing. View "Beckwith v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion for sentence reduction, holding that Defendant was not entitled to relief on his claim that the district court abused its discretion by relying upon the State's misrepresentation of Defendant's criminal history when denying his motion.Defendant pled guilty pursuant to a plea agreement to felony domestic battery and was sentenced to three to six years in prison. Defendant later filed a pro se motion for sentence reduction. The district court denied the motion. The Supreme Court affirmed, holding that where Defendant failed to show that the district court actually relied upon the State's misrepresentation of his criminal history when denying his motion for sentence reduction, the district court did not abuse its discretion by denying the motion. View "Bulisco v. State" on Justia Law

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