Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of first-degree murder, holding that there was no prejudicial error in the proceedings below.After a four-day trial, a jury convicted Defendant of first-degree murder. The district court sentenced Defendant to life imprisonment. The Supreme Court affirmed, holding (1) the circuit court did not err when it determined that Defendant was competent and fit to proceed; (2) the district court did not err when it determined that Defendant's statements to law enforcement were voluntarily made; and (3) there was sufficient evidence of premeditation for a jury to convict Defendant of first-degree murder. View "Snyder v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of obtaining property by false pretenses and ordering her to pay restitution, holding that there was no error in the restitution order.Based on her failure to disclose that she and her children were living with the father of two of her three children, Defendant received overpayments of supplemental nutrition and child care assistance. Defendant pled guilty to obtaining property by false pretenses, received a deferred prosecution, and was ordered to pay restitution. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in awarding restitution that included overpayments for time period during which Defendant asserted she was eligible for assistance; and (2) Defendant waived the question of whether the district court erred when it ordered restitution that included benefits attributable to the father's income. View "Belanger v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions of one count of aiding and abetting attempted second-degree murder, one count of reckless endangering, and one count of misdemeanor possession of methamphetamine, holding that the district court did not err in denying Defendant's request for a jury instruction on the lesser-included offense of accessory to attempted voluntary manslaughter.Defendant was a passenger in her co-defendant's vehicle when the co-defendant led law enforcement on a high speed chase. Defendant was convicted for her part in the crimes committed. The Supreme Court affirmed Defendant's convictions but remanded for correction of the district court's written sentencing order, holding (1) the district court did not err when it declined to give Defendant's proposed jury instruction on the lesser-included offense of accessory to attempted voluntary manslaughter; and (2) the court's written sentencing order deviated from its oral pronouncement. View "Jacobs v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of one count of felony strangulation of a household member and one count of misdemeanor domestic battery, holding that there was no error.On appeal, Defendant argued that the district court violated his due process rights when it refused to allow him to plead guilty to domestic battery and by refusing to accept his guilty plea. The Supreme Court affirmed, holding (1) Defendant failed to establish that he had a protected due process interest in changing his plea to guilty; and (2) the district court did not abuse its discretion when it denied Defendant's request to change his pleas. View "Miller v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of third-degree sexual assault and sentencing him to a sentence of five to eight years in prison, holding that there was no error in the proceedings below.Defendant entered an Alford plea to third-degree sexual assault. On appeal, Defendant argued two arguments relating to his competency at sentencing. The Supreme Court affirmed, holding (1) the district court did not err in imposing Defendant's sentence without first making an oral finding that Defendant was competent to proceed; and (2) the district court did not err by making a written finding that Defendant was competent to proceed with sentencing rather than sua sponte suspending the sentencing hearing and ordering him to undergo a third competency evaluation. View "Merlak v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for attempted second-degree murder, felony property destruction, and other offenses, holding that the district court did not err when it denied Defendant's motion for judgment of acquittal.On appeal, Defendant argued that there was insufficient evidence to support his convictions for property destruction and felony possession of methamphetamine. The Supreme Court disagreed, holding (1) the district court did not err in denying Defendant's motion for a judgment of acquittal on the two property destruction counts because Defendant's conduct provided the required mens rea to impose criminal liability; and (2) the evidence was sufficient for the jury to determine beyond a reasonable doubt that Defendant was guilty of felony possession of methamphetamine. View "Childers v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of strangulation of a household member, holding that there was no error in the district court's evidentiary rulings.On appeal, Defendant argued, among other things, that the district court abused its discretion by admitting recorded phone calls into evidence. As to this evidence, the district court made only a cursory Wyo. R. Evid. 404(b) ruling and did not review any of the Gleason factors. The Supreme Court affirmed, holding (1) Defendant was not prejudiced by the district court's decision to admit evidence that Defendant violated a no-contact order when he called the victim from jail; and (2) the district court did not err when it admitted the victim's hearsay statement recorded on the responding officer's body cam as an excited utterance. View "Jackson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder, holding that the opinion testimony of a forensic pathologist did not materially prejudice Defendant's defense.On appeal, Defendant argued that the district court abused its discretion by admitting improper Wyo. R. Evid. 404(b) of a previous 911 call and surrounding events from 2011 and that the prosecutor's question eliciting the opinion of the forensic pathologist that the cause of death was homicide was plain error. The Supreme Court disagreed, holding (1) the district court did not abuse its discretion when it admitting evidence surrounding the 911 call; and (2) there was no reasonable probability that, absent the prosecutor's question to the forensic pathologist on the cause of death, the verdict would have been more favorable to Defendant. View "Klingbeil v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of three counts of third-degree sexual abuse of a minor between the ages of thirteen and fifteen years, holding that the district court did not improperly instruct the jury on Defendant's theory of defense that he reasonably believed the victim was at least sixteen years old.Specifically at issue was whether the district court erred by defining "reasonable belief" for the jury and by refusing to instruct the jury on the details of Defendant's theory of defense. The Supreme Court affirmed, holding (1) even if the district court erred by providing the definition of "reasonable belief" to the jury, Defendant failed to explain how he was prejudiced by the instruction; and (2) the district court did not err by refusing to provide additional details of Defendant's theory of defense. View "Bernal-Molina v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of two counts of aggravated assault and battery, holding that the district court abused its discretion in allowing the hearsay testimony of two law enforcement officers at trial, but the error was not prejudicial.Specifically, the Supreme Court held (1) the officers' testimony repeating the complaining witness's out-of-court statements was not admissible under Wyo. R. Evid. 801(d)(1)(B); (2) the district court abused its discretion in allowing the officers to testify to the complaining witness's out-of-court statements to explain their investigation; and (3) there was no reasonable probability that the verdict would have been more favorable to Defendant had the improper hearsay evidence not been admitted. View "Thompson v. State" on Justia Law