Justia Criminal Law Opinion Summaries

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

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

The Supreme Court reversed the decision of the district court denying Defendant's motion to suppress evidence discovered after law enforcement entered Defendant's apartment without a warrant to arrest him after he failed to stop for a traffic violation, holding that the district court erred.In denying Defendant's pretrial motion to suppress the district court concluded that the officers' warrantless entry into Defendant's apartment to arrest him was constitutional under the hot pursuit exception to the Fourth Amendment's warrant requirement. The Supreme Court reversed, holding that, under the circumstances, there was no compelling need requiring immediate police action. View "Fuller v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for aggravated animal cruelty and reckless endangering, holding that there was no error and that the evidence was sufficient to support the convictions.Defendant's convictions arose from a dog fight that resulted in a local teenager grabbing Rocky, a boxer, into the street and Defendant, the owner of the other dogs involved in the fight, shooting Rocky as he was held by the teenager. On appeal, Defendant argued that the district court erred in instructing the jury on the law of animal cruelty and that the evidence was insufficient to convict him of reckless endangering. The Supreme Court affirmed, holding (1) Defendant waived his argument that the jury instruction was confusing or misleading; (2) the district court properly denied Defendant's proposed elements instruction; and (3) the evidence was sufficient to sustain the conviction of reckless endangering. View "Mackley v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of being an accessory to both involuntary manslaughter and aggravated assault and battery, holding that the district court erred when it refused to instruct the jury on defense of another.On appeal, Defendant argued that the evidence created a disputed issue of fact as to whether she was an aggressor in the dispute or was acting in defense of the victim throughout the conflict. The Supreme Court agreed, holding (1) defense of another is a recognized defense in this jurisdiction, Defendant's proffered instruction correctly stated the law, and the defense was supported by competent evidence; and (2) therefore, the district court erred when it refused to instruct the jury on defense of another. View "Smith v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony attempted interference with a peace officer and misdemeanor child endangerment, holding that the evidence was sufficient to support the convictions.On appeal, Defendant argued that the officer was not engaged in the lawful performance of his official duties when he used subdued Defendant and that the evidence was insufficient to support the finding that he had the specific intent to disarm the officer. The Supreme Court disagreed, holding (1) the evidence was sufficient to support the jury's finding that the officer did not use excessive force and was therefore engaged in the lawful performance of his duties when he subdued Defendant; and (2) there was sufficient evidence to show Defendant acted with the requisite specific intent. View "Latham v. State" on Justia Law

In this divorce action, the Supreme Court affirmed the judgment of the district court establishing joint custody of the children and failing to require Father to pay Mother retroactive child support, temporary alimony, and attorney fees and costs, holding that the district court did not abuse its discretion.Specifically, the Supreme Court held (1) the district court did not abuse its discretion by awarding the parties joint custody of the children; (2) the district court did not abuse its discretion by refusing to require Father to pay Mother retroactive child support; (3) the district court did not abuse its discretion by failing to require Father to pay Mother temporary alimony and her attorney fees and costs for the district court divorce proceedings; and (4) Father was entitled to his attorney fees and costs under Wyo. Stat. Ann. 20-2-112. View "Sears v. Sears" on Justia Law

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