Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Appellant's motion for sentence reduction pursuant to Wyo. R. Crim. P. 35(b), holding that the district court properly found that it lacked jurisdiction over Appellant's motion.Appellant entered a guilty plea to tattooing a minor, delivery of methamphetamine to a juvenile, and child endangerment. The district court later revoked Appellant's probation and reinstated his original sentence. At issue was Appellant's motion for a sentence reduction that was filed more than one year after Appellant's probation revocation sentence. The district court denied the motion as untimely. The Supreme Court affirmed, holding that Appellant's request for a reduction of sentence was untimely, and therefore, the district court lacked jurisdiction to consider Appellant's motion for a sentence reduction. View "Sherard v. State" on Justia Law

The Supreme Court reversed the judgment of the juvenile court denying RH's petition for expungement of his record pursuant to Wyo. Stat. Ann. 14-6-241, holding that the district court erred in interpreting sections 14-6-241(d) and (e).When RH was sixteen years old the State filed a delinquency petition against him. RH agreed to a deferred prosecution and successfully completed the terms of his deferral. Thereafter, the juvenile court dismissed the delinquency petition. RH later petitioned for expungement of his record. The juvenile court denied the petition, concluding that RH was statutorily ineligible to have the record expunged because the petition charged him with a violent felony. The Supreme Court reversed, holding that section 14-6-241 allows expungement of a juvenile record where a delinquency petition was dismissed but the delinquent act charged was a violent felony. View "RH v. State" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's request for a hearing to show cause and denying his application to remove an interlock device in his car, holding that the district court erred and abused its discretion by denying Defendant's request for a hearing.After he received his tenth driving under the influence (DUI) conviction Defendant was required to operate only vehicles equipped with an ignition interlock device. After eight years of sobriety, Defendant applied to the district court to have the interlock removed pursuant to Wyo. Stat. Ann. 31-5-233(f)(v) and requested a hearing to show cause. The district court denied both requests without explanation. The Supreme Court reversed, holding (1) section 31-5-233(f)(v) requires a court to hold a hearing to allow a defendant to show good cause after he has made a prima facie showing for relief; and (2) the district court was not required to make findings of fact and explain its reasoning. View "Schneider v. State" on Justia Law

The Supreme Court affirmed the order of the district court compelling Defendant to pay $63,428 in restitution to the victim of his offense, Rafael Magana, holding that the district court did not err or abuse its discretion.Specifically, the Supreme Court held (1) the district court had the authority to award restitution to Magana; (2) there was sufficient evidence supporting the district court's award of restitution to Magana; and (3) the district court did not abuse its discretion by failing to consider Magana's comparative fault in determining the amount of restitution. View "Cave v. State" on Justia Law

The Supreme Court affirmed the district court's denial of Defendant's motion to correct an illegal sentence, holding that the district court did not err in denying Defendant's motion.After a jury trial, Defendant was convicted of attempted first-degree murder and was sentenced to prison for the remainder of his natural life. Defendant later filed his motion to correct an illegal sentence under Wyo. R. Crim. P. 35(a). The district court denied the motion without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) Defendant's arguments concerning the validity of his conviction were not reviewable in this Rule 35(a) motion; and (2) Defendant's arguments concerning the legality of his conviction and sentence were barred by res judicata. View "Best v. State" on Justia Law

The Supreme Court reversed Defendant's conviction for third-degree sexual assault and false imprisonment, holding that the district court erred in denying Defendant's motion to transfer his case to juvenile court.Defendant was eighteen years old when the State charged him with offenses that he allegedly committed when he was seventeen years old. When Defendant moved to transfer his case to juvenile court, the State argued that the juvenile court lacked concurrent jurisdiction because Defendant was an adult when the charges were filed against him. The district court dismissed Defendant's transfer motion, concluding that the juvenile court's jurisdiction depended on Defendant's age when he was charged rather than his age when he committed the offense at issue. The Supreme Court reversed, holding that a juvenile court's concurrent jurisdiction under Wyo. Stat. Ann. 14-6-203(c) depends on an offender's age at the time of the offense, rather than at the time charges are filed. View "Rosen v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony murder, second-degree murder, aggravated burglary, and possession of a deadly weapon but remanded the cause for correction of an illegal sentence, holding that the sentence for first-degree felony murder was improper.After convicting Defendant, the district court sentenced Defendant to life in prison for felony murder and ten to fifteen years for aggravated burglary. The Supreme Court affirmed Defendant's conviction but remanded for correction of a sentencing error, holding (1) defense counsel's failure to secure a second psychological evaluation and failure to timely recognize that Defendant had not performed testing did not prejudice Defendant's defense; and (2) the imposition of multiple punishments for felony murder and the underlying felony violated the Double Jeopardy Clauses of the United States and Wyoming constitutions. View "Steplock v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of four felonies - one count of attempted second degree sexual abuse of a minor and three counts of third degree sexual abuse of a minor - holding that Defendant validly waived his right to a jury trial.After a bench trial without any mention in the record that Defendant had waived his right to a jury trial, the court found Defendant guilty of the charged crimes. On appeal, Defendant argued that the court failed to ensure that his jury trial waiver complied with Wyo. R. Crim. P. 23(a) and was knowing, intelligent, and voluntary. The Supreme Court affirmed, holding that Defendant's jury trial waiver was valid. View "Ballard v. State" on Justia Law

The Supreme Court reversed Defendant's conviction for aggravated assault and battery, holding that a new trial was required because the district court abused its discretion by admitting certain testimony that prejudiced Defendant.After a jury trial, Defendant was found guilty for threatening to use a drawn deadly weapon on his wife. On appeal, Defendant argued that the district court abused its discretion by admitting his wife's testimony about a prior incident between her and Defendant in Park City, Utah because the testimony constituted uncharged misconduct evidence that was improperly admitted. The Supreme Court agreed and reversed, holding that the district court abused its discretion in admitting the Park City testimony and that the testimony prejudiced Defendant. View "Kincaid v. State" on Justia Law

The Supreme Court affirmed the order of the district court denying Appellant's motion to correct an illegal sentence, holding that Appellant's claim of an illegal sentence based on the facts supporting his conviction was barred by res judicata.Appellant pled guilty to escape and was sentenced to a two-to-three-year sentence to run concurrent with sentences Appellant had received for other crimes. Appellant later sent a letter that the district court interpreted as a motion to correct illegal sentence under Wyo. R. Crim. P. 35(a). The district court denied the motion as barred by the doctrine of res judicata. The Supreme Court affirmed, holding that Appellant's claim was barred by res judicata because he could have raised the issue in an earlier proceeding. View "Majhanovich v. State" on Justia Law