Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of second-degree sexual abuse of a minor and sentence of two consecutive terms of five to seven years in prison, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued, among other things, that the district court abused its discretion at sentencing by excluding argument and testimony that the victim's parents condoned Defendant's sexual abuse of their daughter and financially extorted him after learning of the abuse. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion at sentencing by refusing to hear argument and testimony that the victim's parents condoned the abuse and used the abuse for financial gain; and (2) properly imposed consecutive sentences of imprisonment rather than probation. View "Villafana v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony shoplifting after a jury trial, holding that the district court did not err or abuse its discretion.On appeal, Defendant argued that his right to a speedy trial was violated and that the district court abused its discretion by allowing a juror who inadvertently saw a video about the trial on social media to remain on the jury. The Supreme Court disagreed and affirmed, holding (1) Defendant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48 or the Sixth Amendment; and (2) Defendant waived any claim related to alleged juror impropriety by not objecting before the return of the verdict. View "Vlahos v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of second-degree murder for the shooting death of his significant other, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the district court did not abuse its discretion when it admitted a certain text message as other acts evidence under Wyo. R. Evid. 404(b); (2) the district court did not abuse its discretion when it permitted the State’s forensic pathologist to opine as to the victim’s manner of death; and (3) there were no clearly improper leading questions involving the prosecutor's personal beliefs or reference to facts not in evidence. View "Anderson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of burglary and other offenses, holding that the district court did not err admitting WiFi records showing Defendant's Apple iPhone connected to his workplace's password-protected WiFI network on the night of the burglary giving rise to Defendant's convictions.Defendant was convicted of burglary, theft, and property destruction for breaking into his workplace and stealing approximately $16,000 in cash. On appeal, Defendant argued that the district court erred in ruling that there was sufficient foundation to allow the WiFi records at issue. The Supreme Court affirmed, holding that assuming that the WiFi records were hearsay, the district court did not abuse its discretion in admitting the evidence under the business records exception. View "Blair v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's pre-sentence motion to withdraw his plea of no contest to second-degree murder, holding that the district court did not abuse its discretion.Defendant pleaded no contest to second-degree murder and guilty to first-degree arson, felony theft, and felony burglary. Before sentencing, Defendant filed a pro se motion to withdraw his no-contest plea, alleging that he made the decision to enter the no-contest plea due to ineffective assistance of counsel. After a hearing, the district court denied the motion, ruling that Defendant failed to establish a basis to withdraw his no-contest plea. The Supreme Court affirmed, holding (1) Defendant failed to meet his burden of establishing there was a fair and just reason to allow him to withdraw his no-contest plea; and (2) the district court correctly exercised its discretion in denying Defendant's motion. View "Pettus v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's pro se motion for a sentence reduction filed under Wyo. R. Crim. P. 35(b), holding that the district court did not violate Defendant's right to due process or abuse its discretion in denying Defendant's motion for sentence reduction.After a jury trial, Defendant was convicted of attempted second-degree murder and sentenced to a term of incarceration of between twenty-five to thirty-five years. Defendant appealed, arguing that the denial of his motion for a sentence reduction was the result of the district judge's personal bias against him. The Supreme Court affirmed, holding (1) Defendant failed to establish bias, and therefore, his due process rights under the Fourteenth Amendment of the United States Constitution were not violated; and (2) the district court did not abuse its discretion in denying Defendant's motion for a sentence reduction. View "Leners v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant, after a jury trial, of second-degree murder and domestic battery, holding that the prosecutors' statements during opening and closing argument did not deprive Defendant of a fair trial.A jury found Defendant guilty of second-degree murder and domestic battery. The district court entered judgment upon the verdict and sentenced him to a term of imprisonment of seventy years to life for the murder. Defendant appealed, arguing that the prosecutors committed misconduct during the State's opening statement and during its closing argument. The Supreme Court affirmed, holding that the challenged statements did not prejudice Defendant. View "Rodriguez v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of voluntary manslaughter, holding that the evidence was sufficient to sustain the conviction and that the district court did not err when it instructed the jury on voluntary manslaughter.Defendant was charged with second-degree murder. The jury acquitted Defendant of the charge and found him guilty of the lesser-included offense of voluntary manslaughter. It also found Defendant guilty of aggravated assault and battery. The Supreme Court affirmed, holding (1) the district court correctly instructed the jury on voluntary manslaughter, and there was the minimal evidentiary support necessary to show Defendant acted in a sudden heat of passion; and (2) the evidence was sufficient to support the jury's verdict. View "Fallon v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated assault and battery with a habitual criminal sentencing enhancement, holding that the district court did not abuse its discretion in admitting the State's recording of certain surveillance footage.At issue on appeal was the district court's admission of the State's cell phone recording of a coffee shop's surveillance footage showing the altercation between Defendant and his victim and whether the government's recording was inadmissible secondary evidence because the State put forth no reasonable effort to obtain the original video before the video surveillance was erased from the system. The Supreme Court affirmed, holding that where the State offered a reasonable explanation for its inability to produce the coffee shop's original surveillance footage and the State did not destroy the original in bad faith, the district court did not abuse its discretion in admitting the State's recording of the footage. View "Baker v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion filed under Wyo. R. App. P. 21 for a new trial based on ineffective assistance of counsel, holding that the district court did not err by denying the motion.After a jury trial, Defendant was convicted of aggravated burglary, aggravated assault and battery, and other crimes after repeatedly confronting his estranged wife and her male friend. On appeal, Defendant argued that the trial court erred in denying his motion for a new trial based on ineffective assistance of counsel. Specifically, Defendant alleged that trial counsel failed properly to advise him of his right to plead not guilty by reason of mental illness. The district court denied the motion, concluding that trial counsel's performance was not deficient. The Supreme Court affirmed, holding that Defendant did not meet his burden to show that prejudice resulted from trial counsel's alleged deficient performance. View "Buckingham v. State" on Justia Law