Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed the judgment of the district court granting the State's petition to revoke Defendant's probation, holding that the district court did not abuse its discretion.Defendant pled guilty to conspiracy to deliver methamphetamine. The district court sentenced Defendant to three to four years of imprisonment but suspended his sentence on the condition that he successfully complete three years of supervised probation. The State subsequently petitioned to revoke Defendant's probation, claiming that Defendant violated a condition in his judgment and sentence. After a hearing, the court revoked Defendant's probation and sentenced him to a term of imprisonment. The Supreme Court affirmed, holding that there was no error or abuse of discretion. View "Farthing v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree murder, holding that Defendant's trial counsel was not ineffective for failing adequately to advise Defendant regarding his right to testify and in failing to present a defense.On appeal, Defendant challenged the district court's denial of his motion for a new trial, arguing that his trial counsel was deficient for denying him the ability to make a knowing and voluntary waiver of the right to testify and for failing to develop and prepare a defense. The Supreme Court affirmed, holding (1) Defendant made a knowing and voluntary decision not to testify; and (2) Defendant's failure to testify was not prejudicial. View "Richmond v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court determining that ASM, a middle-aged woman, needed to be involuntarily hospitalized pursuant to Wyo. Stat. Ann. 25-10-110 because she was mentally ill, as defined under section 25-10-101(a), holding that the district court did not err.Specifically, the Supreme Court held (1) upon review of the entire evidence, including ASM's testimony, the district court did not err when it found ASM to be mentally ill; and (2) the district court did not deny ASM her constitutional right to free exercise of religion under the United States and Wyoming constitutions when it ordered her involuntarily hospitalization in what ASM characterized as a "Catholic ritual of mortification" because ASM failed to establish that she was engaged in such a practice when she injured herself. View "ASM v. State" on Justia Law