Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed Defendant's conviction of sexual abuse of a minor in the second degree, holding that Defendant failed to establish that the district court committed plain error by allowing certain testimony.On appeal, Defendant argued that plain error occurred during trial when the district court allowed State witnesses to vouch for the credibility of other State witnesses and/or to offer opinions as to Defendant's guilt. The Supreme Court disagreed and affirmed, holding (1) the State's witnesses did not vouch for the credibility of other witnesses or offer opinions as to Defendant's guilt; and (2) in the absence of any error, the cumulative error doctrine did not apply. View "Ingersoll v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence, holding that there was no error.Defendant was convicted of three counts of first-degree sexual assault, one count of kidnapping, and one count of aggravated assault and battery. The Supreme Court affirmed on direct appeal. Defendant later filed his motion to correct an illegal sentence, asserting that his sentence violated constitutional prohibitions against double jeopardy. The district court denied relief, determining that Defendant's claims were barred by res judicata and failed on the merits. The Supreme Court affirmed, holding that Defendant's motion to correct an illegal sentence was barred by res judicata. View "Harrell v. State" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence obtained after law enforcement entered her home without a warrant or consent, holding that the district court erred.Defendant entered a conditional plea of guilty to felony driving under the influence. On appeal, Defendant challenged the district court's denial of her motion to suppress, arguing that the record did not support a finding that her husband consented to a law enforcement officer's entry into their home. The Supreme Court reversed and remanded the case, holding (1) the district court erred in concluding that the officer had implied consent to enter the home; and (2) therefore, the officer violated the Fourth Amendment to the United States Constitution. View "Hawken v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment on Defendant's claim of juror misconduct in his petition for postconviction relief, holding that the district court did not err in granting summary judgment on the issue without proceeding to an evidentiary hearing.Defendant, a doctor, was convicted of two counts of the second-degree sexual assault of two of his patients. The convictions were affirmed on appeal. Defendant later filed a petition for postconviction relief, alleging numerous claims. Prior to an evidentiary hearing, the district court granted the State's motion for summary judgment on the issue of juror misconduct. The Supreme Court affirmed, holding (1) Defendant's juror misconduct claim was not procedurally barred; and (2) the district court did not err in granting summary judgment to the State without holding an evidentiary hearing on the claim of juror misconduct. View "Harnetty v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of six counts of first degree sexual assault, two counts of sexual exploitation of a child, and one count of blackmail, holding that there was no error in the proceedings below.On appeal, Defendant argued that the evidence was insufficient to support his convictions for sexual exploitation of a child and argued that the district court abused its discretion in admitting evidence of his prior conviction. The Supreme Court affirmed, holding (1) there was sufficient evidence to support Defendant's convictions for sexual exploitation of a child; and (2) the district court did not err by admitting evidence of Defendant's prior conviction under Wyo. R. Evid. 404(b). View "Barrett v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant, following a jury trial, of various methamphetamine-related offenses and sentencing him to four to eight years in prison, holding that there was no error or abuse of discretion in the proceedings below.Specifically, the Supreme Court held (1) the district court did not err by failing to recuse herself where she previously represented Defendant when she served as a state public defender because Defendant failed to show via affidavit that the judge was biased or prejudiced against him; and (2) the district court did not abuse its discretion by denying without prejudice Defendant's motion in limine to admit certain evidence under Wyo. R. Evid. 608(b). View "Gilbert v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of felony possession of a deadly weapon with unlawful intent, holding that there was no error in the proceedings below.Defendant pleaded nolo contendre to one count of felony possession of a deadly weapon with unlawful intent. Defendant subsequently filed a motion to withdraw his no contest plea pursuant to Wyo. R. Crim. P. 32(d), which the district court denied. After Defendant was sentenced he filed a motion to withdraw his plea pursuant to Wyo. R. App. P. 21. The district court denied the motion. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant's Rule 21 motion to withdraw his plea on grounds of ineffective assistance of counsel; and (2) the district court correctly exercised its discretion in denying Defendant's Rule 32(d) motion because Defendant did not present a fair and just reason for withdrawal. View "Delgado v. State" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of possession of marijuana, holding that the traffic stop in this case was unreasonable under the totality of the circumstances.Defendant was the passenger in a vehicle that was stopped for following a semi-truck too closely. The officer requested a drug-detection canine to be dispatched to the location and subsequently found approximately forty-two pounds of marijuana. Defendant was subsequently charged with two drug-related counts. Defendant moved to suppress the evidence, arguing that the initial traffic stop was unreasonable. The district court denied the motion to suppress, and Defendant entered a guilty plea to count two. The Supreme Court reversed, holding (1) the traffic violation for following too closely was not objectively justified and was unreasonable at its inception; and (2) therefore, the district court erred by denying Defendant's motion to suppress. View "Levenson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of possession of marijuana, aggravated fleeing or attempting to elude, reckless endangering, and interference with a peace officer, holding that the district court did not err in denying Defendant's motion to suppress.Defendant pleaded guilty to the offenses, conditioned on his right to appeal the denial of his motion to suppress the fruits of a traffic stop on the ground that the stop violated the Fourth Amendment. On appeal, the parties disputed whether Defendant waived his constitutional claim by filing an untimely motion to suppress. The Supreme Court affirmed, holding (1) Defendant did not waive his Fourth Amendment claim; and (2) the district court did not err in denying Defendant's motion to suppress. View "Barney v. State" on Justia Law