Justia Criminal Law Opinion Summaries

Articles Posted in Wyoming Supreme Court
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The Supreme Court affirmed the judgment of the district court denying Defendant's Wyo. R. App. P. 21 motion asserting that his trial counsel provided ineffective assistance when he failed to raise a challenge under Batson v. Kentucky, 476 U.S. 79 (1986), holding that the district court did not err.Defendant was convicted of conspiracy to commit aggravated robbery. During trial, the State used two peremptory challenge to strike the only minority jurors in the venire. Defendant's counsel failed to raise a Batson challenge to the State's use of peremptory challenges. The Supreme Court affirmed, holding (1) there is no direct appeal of a Batson claim if it was not raised in the trial court; (2) the failure to raise a Batson challenge is not usually structural error when it is brought in the context of an ineffective assistance of counsel claim; (3) the district court correctly ruled that trial counsel was not ineffective for failing to raise a Batson challenge; and (4) the district court had not duty sua sponte to raise Batson on its own under the facts of this case. View "Yazzie v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence obtained at the end of a traffic stop, holding that the traffic stop was unlawfully extended after its initial purpose had been resolved.Defendant entered a conditional plea to methamphetamine possession and child endangerment. Defendant appealed, arguing that the district court erred in denying his motion to suppress evidence obtained at the end of the traffic stop because the stop was unlawfully extended before a drug dog alerted. The Supreme Court agreed, holding (1) Defendant did not waive his argument that the stop was unlawfully extended; and (2) Defendant's Fourth Amendment rights were violated because the law enforcement officer unlawfully extended the duration of the traffic stop after he completed the citation. View "Mahaffy v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of attempted second-degree murder, holding that the overwhelming evidence of guilt precluded a conclusion that any alleged errors were prejudicial.On appeal, Defendant argued that his counsel provided ineffective assistance and that the prosecutor committed prejudicial misconduct. The Supreme Court affirmed, holding that the district court did not err in denying Defendant's motion for a new trial due to ineffective assistance of counsel and that prosecutorial misconduct did not deny Defendant a fair trial. Specifically, the Court held that Defendant failed to demonstrate prejudice, which was dispositive of both of his claims. View "Leners v. State" on Justia Law

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The Supreme Court affirmed Defendant's sentence imposed in connection with his plea of guilty to escape, holding that the district court properly found that Defendant was not entitled to any credit in this case.Defendant pleaded guilty to escape, and the district court imposed a twenty to forty-month sentence to run consecutive to his underlying sentence. The district court ordered the 111 days Defendant spent in custody prior to his sentence on the escape charge to be credited to his underlying sentence for property destruction. On appeal, Defendant argued that his sentence was illegal because he had not received credit for the 111 days. The Supreme Court affirmed, holding (1) the district court properly credited the time Defendant served after his arrest in the escape case to the underlying property destruction case; and (2) a motion to correct an illegal sentence was not the proper method to challenge the Department of Corrections' administration of a sentence. View "Newnham v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of second-degree murder and aggravated assault, holding that the district court did not err in denying Defendant's motion to suppress statements he made at the scene of the crime and during a recorded interview.On appeal, Defendant argued that the admission of the challenged statements violated his rights under the Fifth and Fourteenth Amendment because he was not informed of his Miranda rights before he was questioned and because he was under the influence of methamphetamine at the time of the recorded interview. The Supreme Court affirmed, holding that the district court (1) did not err when it found Defendant's statements at the scene fell under the public safety exception to Miranda; and (2) did not err when it found that Defendant voluntarily waived his Miranda rights at the police station. View "Schwartz v. State" on Justia Law

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The Supreme Court remanded this criminal case to the district court sentencing Defendant for methamphetamine possession, holding that this Court could not reach the issue on appeal of whether the district court erred when it used Defendant's prior Missouri conviction as a basis for an enhanced sentence under Wyo. Stat. Ann. 35-7-1031(c)(i).Defendant entered into a conditional guilty plea agreement reserving the right to appeal his conviction based on his argument that his prior Missouri convictions did not subject him to enhanced penalties b because they were not violations of a "similar law" under the Wyoming statute. The Supreme Court remanded the case for further proceedings, holding that the Court could not determine from the record which statutes or ordinances underlay Defendant's prior convictions. View "Stanger v. State" on Justia Law

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The Supreme Court affirmed the orders of the district court denying Appellant's motions to correct an illegal sentence and to withdraw his guilty pleas, holding that the district court did not err.Appellant was serving consecutive life sentences for crimes he committed in Washakie County and Carbon County. In these consolidated appeals, Appellant (1) challenged the Washakie County District Court orders denying his motions to correct an illegal sentence and to withdraw his guilty plea and (2) appealed Carbon County District Court orders imposing sentences consecutive to his Washakie County sentence and denying his Wyo. R. Crim. P. 21 motion. The Supreme Court affirmed the Carbon County sentence and the denial of Appellant's Rule 21 motion, holding (1) the Washakie County District Court lacked jurisdiction to consider Defendant's arguments; (2) the Carbon County sentence did not create an unconstitutional de facto life sentence; and (3) Defendant received effective assistance of counsel at his Carbon County resentencing hearing. View "Sides v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction for possession of a controlled substance, holding that the district court did not err in denying Defendant's motion to suppress under the Fourth Amendment to the United States Constitution and Wyo. Const. art. I, 4.A highway patrol trooper stopped Defendant when he twice observed Defendant's vehicle cross the dotted center white line separating the two lanes of traffic. Marijuana was found in a free-air K-9 sniff during the stop. In his motion to suppress, Defendant argued that his failure to maintain a single lane of travel on the two occasions did not create reasonable suspicion justifying the stop of his vehicle. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the district court did not err in concluding that reasonable suspicion supported the initial stop. View "Elmore v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree sexual assault, holding that there was no error in the proceedings below but that remand was required for correction of a clerical error contained in the judgment and sentence.Specifically, the Supreme Court held (1) the district court did not err in denying Defendant's motion for a new trial because Defendant failed to show that trial counsel was constitutionally ineffective; (2) there was sufficient evidence to support a conviction of sexual assault in the first degree; and (3) the district court did not abuse its discretion in using a special verdict form that required the jury to answer questions related to the charged offense before it was required to make a finding of guilt. View "Neidlinger v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court concluding that Defendant was eligible to petition for relief from the duty to register as a sex offender only if he had been registered for twenty-five years, holding that the district court did not err.Thirteen years after his conviction of four-degree sexual assault, now codified as third-degree sexual assault, Defendant began registering as a sex offender when he learned he was obligated to do so by a change in the statute. Twenty-five years after his conviction, Defendant filed a petition seeking to be relieved of the duty to register. The district court granted the petition. When the Division of Criminal Investigation moved for relief from the judgment the district court. The district court granted the motion, holding that Defendant was eligible for relief only after he had been registered for twenty-five years. The Supreme Court affirmed, holding (1) the district court did not err when it interpreted the Wyoming Sex Offender Registration Act (WSORA); (2) the WSORA is not an ex post facto punishment; and (3) Defendant failed to raise a timely or cogent claim that the WSORA violated his constitutional right to protection. View "Harrison v. State" on Justia Law