Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed in part and reversed in part Defendant's convictions for sexual abuse, holding that the failure of the instructions in this case to provide the specific direction necessary for a unanimous decision on each charge violated the unequivocal requirement of jury unanimity, and the error was prejudicial.After a jury trial, Defendant was found guilty of three counts of third-degree sexual abuse of a minor (Counts I, II, and III) and one count of attempted second-degree sexual abuse of a minor (Count VI). On appeal, Defendant argued that the jury instructions, which contained identical language for the basis of conviction on Counts I through V, were insufficient to direct the jury to a unanimous verdict on each count. The Supreme Court agreed and reversed Defendant's convictions and Counts II and III, holding that the district court's failure to properly instruct the jury violated a clear and unequivocal rule of law that adversely affected Defendant's substantial rights. View "Walker v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court convicting Defendant of second-degree murder after denying his motion to suppress, holding that the district court erred in determining when Defendant's interrogation became custodial, and that error required reversal.Specifically, the Supreme Court held (1) the district court erred in ruling that Defendant was not in custody during his police station interview until he was directed to remain in an interview room; (2) it was not harmless error to admit incriminating statements Defendant made after his interrogation became custodial; and (3) the record supported the district court's conclusion that Defendant's confession was voluntary. View "Mills v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of aggravated assault and battery for shooting a man at a campground, holding that the district court erred when it refused to give Defendant's proposed "castle doctrine" instructions.Defendant was charged with aggravated assault and battery in violation of Wyo. Stat. 6-2-502. Defendant filed a motion to dismiss arguing that he had acted in self-defense and was immune from prosecution under the "castle doctrine." See Wyo. Stat. 6-2-602(f). The district court denied the motion to dismiss, and a jury convicted Defendant of aggravated assault and battery. On appeal, Defendant argued the district court erred when it refused to give his proposed castle doctrine instructions. The Supreme Court reversed, holding (1) Defendant presented competent evidence to create factual issues about whether his vehicle was adapted for overnight accommodation and fit within the definition of "habitation" and whether the victim was in the process of unlawfully and forcefully entering that habitation when he was shot; and (2) because the district court did not allow these factual questions be resolved by the jury, a new trial was required. View "Howitt v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for two counts of felony child endangerment and one count of misdemeanor possession of methamphetamine, holding that the prosecutor's comments during opening and closing statements were not prejudicial to Defendant.After a jury trial, Defendant was convicted of two counts of felony child endangerment and one count of misdemeanor possession of a controlled substance. The district court sentenced Defendant to three to five years in prison for the endangerment counts, to run concurrently with each other. The Supreme Court affirmed, holding that Defendant failed to establish that two almost identical statements made by the prosecutor before trial denied Defendant a substantial right or materially prejudiced his case. View "Lott v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of felony property destruction and defacement, holding that there was sufficient evidence to support the conviction and that the prosecutor did not commit misconduct during his rebuttal argument.After a jury trial, Defendant was found guilty of felony property destruction and defacement. Defendant appealed, arguing that there was insufficient evidence to support his conviction and that a statement made during the prosecutor's rebuttal closing argument amounted to misconduct. The Supreme Court affirmed, holding (1) sufficient evidence supported the conviction; and (2) the prosecutor did not engage in misconduct during rebuttal closing argument. View "Ogden v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony property destruction, sentencing him to a term of imprisonment and probation, and ordering restitution in favor of the victim, holding that there was no error in the restitution order.Defendant pled guilty to felony property destruction. The district court sentenced Defendant to three to five years in prison, suspended in favor of the three years of probation. The district court then ordered restitution in the amount of $7,398. Defendant appealed, challenging the sufficiency of the evidence supporting the restitution award. The Supreme Court affirmed, holding that Defendant waived his right to contest the factual basis for the court's restitution order when he failed timely to object to the victim's damages identified in the presentence investigation report. View "Corr v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Appellant's declaratory judgment action against Wyoming Governor Mark Gordon and the Wyoming Board of Parole, holding that the district court did not err in concluding that Appellant lacked standing to bring his claims.Appellant, an inmate serving a life sentence and a consecutive five-to-ten-year sentence for crimes to which he pled guilty in 1989, brought this action seeking a declaration that Wyoming's commutation procedures are unconstitutional. The district court dismissed the action, concluding that Appellant lacked standing and that Wyoming's commutation procedures did not violate Appellant's constitutional rights. The Supreme Court affirmed, holding (1) because Appellant did not have an existing or genuine interest in or right to commutation he lacked standing to bring his declaratory judgment action; and (2) commutation decisions involve a political question that is not an appropriate subject for judicial review. View "Weldon v. Honorable Mark Gordon" on Justia Law