Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Defendant's Wyo. R. Crim. P. 35(b) motion for a sentence reduction, holding that the district court did not abuse its discretion.Defendant pled guilty to one count of second degree sexual abuse pursuant to a plea agreement. The district court sentenced Defendant to a prison term of twelve to fifteen years. Defendant later filed a motion for sentence reduction, citing the progress that he had made since his incarceration. The district court denied the motion. The Supreme Court affirmed, holding that Defendant's sentence was within the sentencing range, and the district court did not abuse its discretion denying a reduction. View "Coffey v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court revoking Defendant's probation, holding that the district court did not abuse its discretion when it concluded that Defendant willfully violated his probation when he missed a meeting with his probation agent and used methamphetamine.In 2018, Defendant was found guilty of two counts of possession of a controlled substance. In 2020, the State moved to revoke Defendant's probation, alleging that Defendant, among other things, willfully used methamphetamine. The district court found that Defendant willfully violated his probation and revoked Defendant's probation and imposed the underlying sentence. The Supreme Court affirmed, holding that the district court's finding that Defendant willfully used and admitted to using methamphetamine was not clearly erroneous. View "Ramos v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for three counts of first-degree sexual abuse of a minor, holding that the district court did not commit prejudicial error in admitting evidence of prior bad acts under Wyo. R. Evid. 404(b) and by refusing to conduct a pretrial taint hearing.On appeal, Defendant argued, among other things, that had the trial court considered the factors set forth in Gleason v. State, 57 P.3d 332 (Wyo. 2002) before admitting the 404(b) evidence, the evidence would not have been admissible at trial. The Supreme Court disagreed, holding (1) the admission of the 404(b) evidence did not prejudice Defendant because, even without the evidence of Defendant's prior uncharged conduct, there was no reasonable probability that the jury would have reached a different conclusion; and (2) the district court did not abuse its discretion in concluding that the victim was competent without further consideration of evidence of taint. View "Miller v. State" on Justia Law

The Supreme Court dismissed this appeal from the judgment of the district court accepting Defendant's plea of no contest to stalking but declining to enter a conviction on the plea, deferring the proceedings, and placing Defendant on one year of unsupervised probation, holding that this Court lacked jurisdiction.On February 27, 2020, the district court signed the sentencing order and, the next day, e-mailed the sentencing order to the district court. On March 3, 2020, the hard copy of the sentencing order was filed of record. On April 2, 2020, Defendant filed her notice of appeal. The Supreme Court dismissed the appeal, holding that Defendant's appeal was untimely, and therefore, this Court lacked jurisdiction. View "Raczon v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's pro se complaint filed under the Uniform Declaratory Judgments Act alleging that the Wyoming Department of Corrections (WDOC) inmate classification policies are invalid rules, holding that the WDOC's inmate classification policy is not a rule required to be filed with the Wyoming Secretary of State.Plaintiff pled guilty to kidnapping and first-degree sexual assault and was sentenced to two concurrent life sentences. In his complaint for declaratory judgment Plaintiff alleged that the failure to file WDOC policies and procedures with the Secretary of State rendered them, and any actions taken pursuant to them, void. Therefore, Plaintiff claimed that his recent inmate classification was void. The district court dismissed the complaint. The Supreme Court affirmed, holding that the WDOC was not required to file the inmate classification policy at issue with the Secretary of State's office, and therefore, Plaintiff failed to state a claim upon which relief can be granted. View "Bird v. Lampert" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence, holding that Defendant's claim was barred by res judicata.Defendant pled guilty to two counts of forgery, two counts of burglary, and one count of aggravated burglary. Defendant challenged his sentences on multiple occasions. At issue on appeal were Defendant's two motions to correct an illegal sentence, filed in 2018 and 2020. The district court denied both motions. On appeal from the denial of his latest motion, Defendant argued that he was entitled to credit against his Wyoming sentences for time spent in Colorado. The Supreme Court affirmed, holding that because Defendant already litigated his claim, he was now barred from raising that claim. View "Russell v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree sexual assault, holding that the State's delay in bringing charges against him did not violate due process and that the prosecutor's comments during closing argument did not constitute plain error.On appeal, Defendant argued, among other things, that the prosecutor improperly commented on his right to remain silent during closing argument. The Supreme Court disagreed, holding (1) Defendant failed to show that the State's delay in charging him violated his right to due process; and (2) Defendant failed to show that the prosecutor's statements during closing argument violated a clear and unequivocal rule of law in a clear and obvious way. View "Ridinger v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of third-degree sexual abuse of a minor, TM, holding that the district court did not commit plain error by admitting evidence of TM's out-of-court statements about the abuse.On appeal, Defendant argued that the district court erred by admitting into evidence TM's prior consistent out-of-court statements and by allowing the jury to review, during deliberations, a clip of a muted video of Defendant and a police officer walking through the bedroom where the abuse occurred. The Supreme Court affirmed, holding (1) the district court's admission of TM's out-of-court statements about the abuse was proper; and (2) Defendant failed to demonstrate that there was a reasonable probability the verdict would have been more favorable to him if the district court had refused the jury's request to view the contested video. View "Hicks v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court revoking Defendant's probation, holding that the State presented sufficient evidence to prove that Defendant violated the terms of his probation, and the district court did not abuse its discretion by ordering the revocation.Defendant pleaded guilty to several burglaries and was sentenced to a term of imprisonment, suspended in favor of probation. The State later moved to revoke Defendant's probation not he grounds that he violated the terms by committing the crime of attempted burglary. The district court revoked Defendant's probation. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it determined that the State had proved that Defendant violated his probation by a preponderance of the evidence. View "Stroble 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 err in denying Defendant's motion for judgment of acquittal, the evidence was sufficient to support the conviction, and the prosecutor made two improper statements in rebuttal argument, but the statements did not prejudice Defendant when considered together.Specifically, the Supreme Court held (1) the State produced sufficient evidence of "touching under the statutory definition of sexual contact and evidence that Defendant touched the victim with the "intent of sexual arousal, gratification, or abuse"; and (2) the prosecutor made two improper statements during rebuttal argument, but, cumulatively, the improper statements did not deprive Defendant of a fair trial. View "Armajo v. State" on Justia Law