Justia Criminal Law Opinion Summaries

In this case, appellant Ismael Ruiz sought to appeal the dismissal of his motion for a sentence reduction by the District Court of Sweetwater County, Wyoming, arguing that the court had erred in ruling it did not have jurisdiction over his motion. The Supreme Court, State of Wyoming found that Ruiz had filed his motion for sentence reduction beyond the one-year deadline stipulated by Wyoming Rule of Criminal Procedure (W.R.Cr.P.) 35(b). Therefore, the District Court correctly concluded it lacked jurisdiction over the motion. As a result, the Supreme Court, State of Wyoming also lacked jurisdiction to consider the appeal and dismissed it. The details of the case involve Ruiz's 2018 conviction for aggravated assault and battery, for which he was sentenced to seven to ten years in prison but placed on supervised probation for five years. After violating his probation in 2019, the original prison sentence was imposed. Ruiz attempted multiple times to have his sentence reduced or his conviction overturned, with all motions being dismissed by the District Court due to untimeliness or lack of jurisdiction. View "Ruiz v. The State of Wyoming" on Justia Law

In a case before the Supreme Court of the State of Wyoming, appellant Darrell Leonardo Alexander claimed that the district court erred in denying his motion to suppress evidence obtained by law enforcement after they entered his apartment without a warrant or his consent. The case revolved around the question of warrantless entry and consent.The court held that the warrantless entry into Alexander's apartment did not violate the Fourth Amendment. This was because the officers reasonably believed that Alexander's girlfriend, identified as E.B., had the apparent authority to consent to their entry. E.B. had called the police to report domestic violence, and when the officers arrived, she opened the door to the apartment and stepped inside, holding the door open for the officers. This action was seen as an invitation for the officers to enter the apartment.The court also found that E.B. had given implied consent for the officers to enter the apartment based on her nonverbal gestures and actions, such as opening the door and stepping inside when asked about the location of her boyfriend. Considering the totality of the circumstances, the court ruled that the officers' reliance on E.B.'s apparent authority to consent to their entry was reasonable. As such, the district court's decision to deny Alexander's motion to suppress the evidence was affirmed. View "Alexander v. The State of Wyoming" on Justia Law

Travis James Wright, found guilty of two counts of sexual exploitation of children, appealed the denial of his motion for sentence reduction by the District Court of Carbon County. He had been sentenced to two concurrent sentences of eight to ten years. Wright filed a pro se motion for sentence reduction, arguing prosecutorial misconduct, the proportionality of his sentence, and providing personal information and letters of support. The Supreme Court of Wyoming affirmed the lower court's decision, noting that the district court did not abuse its discretion in denying the motion. The court explained that it reviews rulings on motions for sentence reduction for abuse of discretion, and the sentencing judge is in the best position to decide about sentence modification. The court found that Wright's claims were not supported by cogent argument and were not appropriate under a Rule 35(b) motion, which cannot be used to attack the validity of a conviction or as a substitute for a properly filed appeal. The court also noted that productive behavior alone does not require the district court to grant a sentence reduction. View "Wright v. The State of Wyoming" on Justia Law

In a case before the Supreme Court of Wyoming, Kristina Croy, a daycare operator, was found guilty of involuntary manslaughter following a six-day jury trial. The charges stemmed from an incident in which an eight-month-old infant, MG, in her care died due to positional asphyxia resulting from being improperly swaddled. Croy appealed, arguing, among other things, that there was insufficient evidence to support the jury's verdict. The Court affirmed the conviction, stating there was sufficient evidence for the jury to conclude that swaddling MG posed a substantial and unjustifiable risk of death, and that Croy had consciously disregarded that risk. The Court also ruled that the trial court did not abuse its discretion when it dismissed a juror who had discussed the case with another juror prior to deliberations, violating the court's instructions not to prejudge the case. Furthermore, the Court determined that the trial court did not abuse its discretion or deprive Croy of a fair trial when it declined her request to impose restrictions on how the State split its time between closing summation and rebuttal argument. The Court's decision was based on the particular facts of the case, noting that Croy could not demonstrate that there was a reasonable probability the verdict might have been more favorable to her if the prosecutor had not been allowed to make a lengthy rebuttal argument. View "Croy v. The State of Wyoming" on Justia Law

In a car accident resulting in the death of a motorcyclist, the driver, Yvonne Patrice Kessel, was convicted of one count of aggravated vehicular homicide. The State of Wyoming Supreme Court affirmed the conviction, holding that Kessel’s proposed jury instruction, which suggested that the jury could consider the victim’s actions when determining proximate cause, was not a proper theory of defense. The Court found that Kessel was essentially arguing that the State failed to prove the proximate cause element of the charged offense, which it deemed a "claim of innocence" or "failure of proof" defense not warranting a special theory of defense instruction. The Court also ruled that the jury had been adequately instructed on the concept of proximate cause and that the instructions allowed both parties to argue their respective theories of the case. Thus, the Court concluded that the lower court did not abuse its discretion by denying Kessel’s proposed instruction. View "Kessel v. The State of Wyoming" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence under Wyo. R. Crim. P. 35(a), holding that the district court did not err in concluding that Defendant's motion was barred by res judicata.Defendant was convicted of two counts of aggravated vehicular homicide and sentenced to twelve to twenty years in prison on each count, to be served consecutively. After unsuccessfully moving in 2015 to correct an illegal sentence, in 2022 Defendant filed the current motion to correct an illegal sentence, arguing that his consecutive sentences were illegal because they exceeded the twenty-year statutory maximum sentence for aggravated vehicular homicide. The district court denied the motion on res judicata grounds. The Supreme Court affirmed, holding that because Defendant already raised and litigated the claim presented in his current motion, the district court did not err in denying the Rule 35(a) motion on res judicata grounds. View "Tucker v. State" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion in his criminal case for the return of property seized by law enforcement during the underlying criminal investigation, holding that remand was required.Defendant pleaded guilty to aggravated assault and battery. Several months after he was sentenced Defendant filed a motion requesting suppression of items used as evidence in his case. The district court ruled that it did not have jurisdiction over Defendant's motion in the criminal case because a post-conviction motion for return of property is a civil matter. The Supreme Court reversed, holding that the district court erred in declaring that it did not have jurisdiction to consider Defendant's motion for return of his property, nor did it have the legal authority to order return of the property because the motion was authorized by Wyo. R. Crim. P. 41(d), and the court should have received evidence to determine whether Defendant was entitled to return of the property. View "Bunten v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence, holding that the district court did not err in ruling that res judicata barred Defendant's motion to correct an illegal sentence.Defendant was convicted of second-degree abuse of a minor and soliciting a minor to engage in sexual relations and sentenced to twenty years as to the sexual abuse conviction and to four to five years on the solicitation conviction, to be served consecutively. Defendant later filed a pro se motion to correct an illegal sentence, arguing that the acts underlying his conviction were one continuous act and that his consecutive sentences violated double jeopardy protections. The district court denied relief ruling that res judicata barred the motion. The Supreme Court affirmed, holding (1) a motion to correct an illegal sentence can be subject to res judicata; and (2) the interests of res judictata in finality and avoiding repetitive litigation were served in this case. View "Peterson v. State" on Justia Law

The Supreme Court affirmed the decision of the district court denying Appellant's motion to correct an illegal sentence, holding that the district court correctly concluded that Appellant was not entitled to credit for time spent on probation when he was resentenced in a probation revocation proceeding.Defendant admitted to the State's allegations of probation violations, and his probation was revoked and sentence reinstated. Defendant filed a motion to correct an illegal sentence, claiming that he was entitled to credit for time spent on supervised probation, inclusive of inpatient substance abuse treatment and participation in Treatment Court. The district court denied the motion. Defendant subsequently moved both a second and third time to correct an illegal sentence, without success. Defendant appealed the district court order denying his first request to correct an illegal sentence. The Supreme Court affirmed, holding that the district court properly denied the motion. View "Stevenson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for interference with a peace officer, holding that the district court did not violate Defendant's due process rights by conducting a hearing under Asch v. State, 62 P.3d 945 (Wyo. 2003), in Defendant's absence after he refused to attend the hearing.Defendant, who was serving three consecutive life sentences at the Wyoming State Penitentiary, was charged with interference with a peace officer. Before the scheduled trial date, the State moved to require Defendant to be restrained during trial. The district court conducted an Asch hearing without Defendant and decided to impose restraints at trial. Defendant was convicted of one count of felony interference with a peace officer. The Supreme Court affirmed, holding that Defendant waived any right he had to be present at the Asch hearing by knowingly and voluntarily failing to appear at the hearing due to circumstances within his control. View "Castellanos v. State" on Justia Law