Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to transfer his case to juvenile court, holding that the district court did not abuse its discretion in denying the motion to transfer the case to juvenile court.Defendant, a minor, was arrested and charged with nine counts of attempted first-degree minor after taking guns and ammunition to his high school planning to shoot nine particular individuals and as many other people as he could. Defendant filed a motion to transfer his case to juvenile court, but the motion was denied. The Supreme Court affirmed, holding that the district court appropriately analyzed and weighed the applicable factors under Wyo. Stat. Ann. 14-6-237(b) and did not abuse its discretion in denying Defendant's motion to transfer. View "Warner v. State" on Justia Law

The Supreme Court affirmed the decision of the Office of Administrative Hearings (OAH) upholding the decision of the Wyoming Department of Transportation (WYDOT) suspending Defendant's driver's license and operating privileges pursuant to Wyo. Stat. Ann. 31-6-102(e), holding that the OAH reasonably concluded as it did.Defendant was arrested for driving under the influence of alcohol. Because a breathalyzer test indicated that Defendant had a blood alcohol concentration greater than .08% the WYDOT suspended Defendant's driver's license. The OAH upheld the suspension. The Supreme Court affirmed, holding that substantial evidence supported the OAH's finding that law enforcement did not interfere with Defendant's right to obtain an independent chemical test under Wyo. Stat. Ann. 31-6-102(a)(ii)(C) and 31-6-105(d). View "Flauding v. State ex rel. Wyoming Department of Transportation" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of aggravated assault and battery, holding that prosecutorial misconduct did not prejudice Defendant.At trial, Defendant requested that the jury be instructed on self-defense. On appeal, Defendant argued that the prosecutor committed misconduct at trial when she misstated the law of self-defense to the jury three different times. The Supreme Court affirmed, holding that the prosecutor in this case did not misstate the law and that Defendant failed to show how the prosecutor's comments, considered cumulatively, prejudiced him. View "Mendoza v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of eight counts of forgery, holding that the district court did not err or abuse its discretion.On appeal, Defendant argued that the evidence was insufficient to show an intent to defraud and that the district court erred in instructing the jury on the required intent to defraud. The Supreme Court affirmed, holding that the district court (1) did not err in denying Defendant's motion for judgment of acquittal; and (2) did not abuse its discretion when it instructed the jury on the required element of intent to defraud. View "Bezold v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree sexual abuse of a minor, holding that the district court did not violate Defendant's right to a speedy trial.The State originally charged Defendant with one count of first-degree sexual assault and one count of delivery of a controlled substance, but sixteen days before trial, the State amended its information to include one count of second-degree sexual abuse of a minor. After a jury trial, Defendant was found guilty of second-degree sexual abuse of a minor. The Supreme Court affirmed, holding (1) Defendant's argument that the amendment to the indictment was untimely was waived because he failed to raise it below; and (2) Defendant was not deprived of his right to a speedy trial. View "Rogers v. State" on Justia Law

The Supreme Court affirmed the district court's denial of Defendant's pre-sentence motion to withdraw guilty plea, holding that there was no error in the proceedings below.In 2020, the State filed a third petition to revoke Defendant's probation. Following the revocation proceeding, Defendant filed a motion to withdraw the guilty plea he had entered in 2017 on the grounds that the testimony he gave to support his plea was insufficient to establish a factual basis. The district court denied the motion. Thereafter, the court entered an order revoking Defendant's probation and entered judgment convicting him of burglary. The Supreme Court affirmed, holding that the district court properly denied Defendant's motion to withdraw his guilty plea because a sufficient factual basis existed for the plea. View "Reid v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming Defendant's license suspension, holding that law enforcement officers did not deprive Defendant of his right to an independent chemical test of his blood alcohol content, and therefore, his statutory and due process rights were not violated.Defendant was arrested for driving while under the influence of alcohol. Defendant submitted to a chemical breath test, which indicated that his blood alcohol concentration exceeded the legal limit. Defendant was advised of his right to obtain an independent chemical test at his own expense, and Defendant chose to exercise it. Defendant, however, never obtained the test. The Wyoming Department of Transportation suspended Defendant's driver's license for ninety days. Both the Office of Administrative Hearings and district court upheld the suspension. The Supreme Court affirmed, holding (1) substantial evidence supported the finding that law enforcement officers did not interfere with Defendant's right to obtain an independent blood test; and (2) the relevant statutes and substantive due process did not require law enforcement officers to do more than allow Defendant to go to the nearest hospital or clinic to obtain a test. View "Johnson v. State ex rel., Wyoming Department of Transportation" on Justia Law