Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed Defendant's conviction of three counts of delivery of a controlled substance, holding that the exclusion of "distilled spirits, wine, malt beverages, or tobacco" from the Wyoming Controlled Substances Act, Wyo. Stat. Ann. 35-7-1031(a)(ii), did not violate Defendant's constitutional equal protection rights.In his motion to dismiss, Defendant argued that the Act violated his rights to equal protection and substantive due process under the United States and Wyoming Constitutions by operating in an unequal and disparate manner because the Act excludes from its application tobacco and alcohol. The district court denied the motion to dismiss. The Supreme Court affirmed, holding that the regulation of substances contained in the Act was reasonably related to the State's legitimate interests and did not violate Defendant's constitutional right to equal protection. View "Hardison v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of possession of methamphetamine, possession of marijuana, and interference with a peace officer, holding that there was sufficient evidence to support Defendant's conviction for marijuana possession.During trial, the prosecution presented testimony that the green leafy substance found in Defendant's left from pocket was consistent with marijuana, but there was no testimony on the concentration of the substance's THC concentration. On appeal, Defendant argued that, in the absence of proof of the THC concentration, there was insufficient evidence to support his conviction for possession of marijuana. The Supreme Court affirmed, holding (1) under Wyo. Stat. Ann. 35-7-1050(a), Defendant bore the burden of establishing that the substance he possessed had a THC concentration of not more than 0.3 percent; and (2) Defendant failed to meet his burden of proof and made no argument that the evidence was otherwise insufficient to support his conviction. View "Roman v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony child endangerment, holding that the evidence was sufficient to support the conviction.After a bench trial, the district court found Defendant guilty of felony child endangerment. At the close of the State's evidence, Defendant moved for judgment of acquittal, alleging that the State had failed to provide sufficient evidence of the elements necessary to convict her. The district court denied the motion. The Supreme Court affirmed, holding that the State presented sufficient evidence to sustain a conviction for child endangerment, and therefore, the district court did not err in denying Defendant's motion for judgment of acquittal. View "Reyes v. State" on Justia Law