Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed the decision of the district court denying Appellant's post-sentence motions to withdraw his no contest pleas in two separate dockets, holding that the district court did not abuse its discretion in denying Appellant's motions to withdraw his no contest pleas.In one docket, Appellant was charged with one count of burglary. In the other docket, Appellant was charged with one count each of attempted murder and aggravated assault. Pursuant to a plea agreement, Appellant entered a plea of no contest to attempted voluntary manslaughter and burglary. After the sentence was imposed, Appellant unsuccessfully filed motions to withdraw substitution of counsel in both dockets, motions requesting to withdraw his pleas of no contest, and motions in arguing ineffective assistance of counsel. The Supreme Court affirmed the denial of Appellant's motions to withdraw his no contest pleas, holding that there was no abuse of discretion. View "Sena v. State" on Justia Law

The Supreme Court affirmed the order of the district court adjudicating JP delinquent and the corresponding order of disposition, holding that Defendant did not receive ineffective assistance of counsel when his attorney failed timely to demand a jury trial.The State filed a delinquency petition alleging that seventeen-year-old JP inflicted sexual intrusion on a thirteen-year-old girl. After a hearing, the juvenile court found that JP committed a delinquent act and sentenced him to one year of juvenile probation. On appeal, JP argued that he was prejudiced by his counsel's failure to timely demand a jury trial. The Supreme Court affirmed, holding that JP failed to show the outcome of his case would have been different if it had been tried to a jury. View "JP v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of sexual assault in the third degree, holding that the district court did not err when it allowed the State to amend the felony information before submitting the case to the jury.The State charged Defendant by felony information with three identical counts of sexual assault in the third degree. Before trial, the district court asked the State to differentiate the charges, but the court did not act immediately on the request. After the State's presentation of evidence Defendant moved for a judgment of acquittal on the ground that the felony information did not differentiate between the counts. The district court denied the motion and granted the State's motion to amend the felony information. After Defendant was convicted he appealed. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it allowed the State to amend the felony information during trial; and (2) Defendant's substantial rights were not prejudiced by the amendment. View "Roberts v. State" on Justia Law

The Supreme Court reversed the judgment of the district court sentencing Defendant to the maximum term of fifteen to twenty years for aggravated vehicular homicide and a concurrent six months for driving under the influence, holding that the district court plainly erred when it considered Defendant's silence and community expectations in sentencing her.On appeal, Defendant argued that her constitutional right to a fair sentence was violated when the district court "emphasized, and likely punished, her decision to exercise her constitutional rights at the time of her arrest" and when the court expressed that "the severity of the sentence depended upon the county in which it presided over her." The Supreme Court agreed and remanded the case for a new sentencing hearing, holding that the district court erroneously incorporated constitutionally-prohibited factors into its sentencing decision and that the application of those constitutionally-prohibited factors in sentencing undermined the fairness and integrity of the judicial proceedings. View "Jewkes v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court modifying Father's child support order and ordering Father to pay $4,596.71 in child support arrears, holding that the district court did not abuse its discretion.In 2012, the district court entered an order establishing custody and support for Father's and Mother's children. The Department of Family Services, Child Support Enforcement Division later filed a petition to modify Father's child support order. Father answered, requesting that he be relieved of his child support arrears. The district court denied Father's request for relief, modified the child support order, and ordered Father to pay child support arrears. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it denied Father's request for relief from the 2012 child support order. View "Carroll v. State ex rel. Department of Family Services" on Justia Law

The Supreme Court affirmed Defendant's conviction of attempted first-degree arson, entered after a jury trial, holding that the evidence was sufficient to support the conviction and that the district court did not commit plain error by allowing a police officer to testify that gasoline is an accelerant.On appeal, Defendant argued that the State presented insufficient evidence to support his attempted first-degree arson conviction and that a police officer improperly opined as an expert that a liquid he identified as gasoline found in Defendant's home was an accelerant despite not being qualified to testify as an expert under Wyo. R. Evid. 702. The Supreme Court affirmed, holding (1) sufficient evidence supported the conviction; and (2) as to his remaining assignment of error, Defendant failed to satisfy the second prong of plain error review. View "Esquibel v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for misdemeanor stalking and strangulation of a household member, entered upon his guilty plea, holding that Defendant gave a sufficient factual basis to support his guilty plea.At the change of plea hearing when he was asked about the factual basis for the counts, Defendant did not give detailed answers, instead providing "yes" answers to the questions of both counsel and the court. After Defendant's attorney questioned him, the trial court found there was a factual basis for both counts and accepted Defendant's plea. The Supreme Court affirmed, holding that the district court did not violate a clear and unequivocal rule of law when it accepted his guilty plea. View "Beeson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony possession of marijuana, entered following Defendant's conditional guilty plea, holding that the initial traffic stop of Defendant in this case comported with the requirements of the Fourth Amendment to the United States Constitution.In denying Defendant's motion to suppress, the trial court concluded that the initial traffic stop was justified as a drug trafficking investigation. Defendant appealed, arguing that the district court erred in concluding the officer had reasonable suspicion to stop Defendant based on the collective knowledge doctrine. The Supreme Court affirmed, holding that the initial stop was legally justified under the Fourth Amendment, and therefore, the district court did not err in denying Defendant's motion to suppress. View "Guandong v. State" on Justia Law