Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of one count of sexual abuse of a minor in the second degree, holding that the admission of Wyo. R. Evid. 404(b) evidence was not prejudicial error.On appeal, Defendant argued that the State introduced improper Rule 404(b) evidence by eliciting testimony from the victim about an earlier incident when she and Defendant were wrestling. The Supreme Court affirmed, holding (1) the testimony regarding the wrestling incident implicated Rule 404(b); but (2) Defendant was not prejudiced because there was no reasonable probability that the verdict would have been more favorable had the wrestling incident evidence not been admitted. View "Cox v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions, holding that Defendant failed to prove that the district court abused its discretion in its evidentiary rulings and challenged jury instructions and failed to prove the evidence was insufficient to convict him.Specifically, the Supreme Court held (1) the district court did not abuse its discretion when it allowed the State to play a recorded phone call between Defendant and his co-defendant; (2) the district court did not abuse its discretion when it refused to give Defendant's proposed modification to the pattern jury instruction on possession; and (3) the evidence was sufficient to support Defendant's convictions. View "Mitchell v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony theft, holding that Defendant was not denied his constitutional right to a speedy trial.On October 2, 2017, Defendant was arrested for the theft of a vehicle. While he was detained in Natrona County, Fremont County filed charges against him for the theft of another vehicle. Fremont County filed an information but did not pursue further prosecution on the charges for 481 days. During that time, Defendant was convicted in Natrona County and began serving a sentence. On September 26, 2019, Defendant filed a motion to dismiss the Fremont County charges for lack of a speedy trial. The district court denied the motion. Defendant then entered into a conditional guilty plea agreement. On appeal, Defendant argued that he was denied his constitutional right to a speedy trial. The Supreme Court affirmed, holding that Defendant's constitutional right to a speedy trial was not violated. View "Crebs v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of attempted aggravated robbery, holding that the district court did not commit judicial misconduct or deprive Defendant of a fair trial by commenting on the foundation for admission of the gun used in the robbery and did not abuse its discretion by denying Defendant's motion for a mistrial.On appeal, Defendant argued that the district court committed misconduct by explaining to the State how to lay the foundation for admission into evidence of the gun and erred by denying his motion for a mistrial after the State elicited an answer from a witness in violation of an order in limine. The Supreme Court affirmed, holding (1) the district court did not deprive Defendant of a fair trial; and (2) although the witness's testimony violated the order in limine the district court properly concluded that the error was not so prejudicial that it denied Defendant a fair trial. View "Langley v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of aggravated felony child abuse, holding that the district court did not err in admitting Wyo. R. Evid. 404(b) evidence from misconduct that was originally charged but dismissed by the circuit court.Defendant was convicted of inflicting injuries on a minor child, PS on November 2 and November 3, 2018. On appeal, Defendant argued that the district court erred in admitting evidence related to an incident on September 10, 2018, in which Defendant admitted that he threw a bottle at PS and bruised her head. Specifically, Defendant argued that it was improper to admit the evidence under Wyo. R. Evid. 404(b) because the evidence related to a charge dismissed at the preliminary hearing. The Supreme Court disagreed, holding that the district court did not err in admitting the evidence surrounding the September 10, 2018 incident. View "Putnam v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of possession of methamphetamine, possession with intent to deliver methamphetamine, and conspiracy to deliver methamphetamine, holding that the district court did not err in denying Defendant's motion to suppress.After Wyoming Division of Criminal Investigation agents gathered information that Defendant was selling methamphetamine they installed a GPS tracking device on his truck. Wyoming Highway Patrol Troopers initiated a traffic stop of Defendant based on a crack in the front windshield of his truck. After a search, drugs and drug paraphernalia were discovered. Defendant moved to suppress, which the trial court denied. The Supreme Court affirmed, holding that the Troopers had reasonable suspicion to stop the truck for driving with a crack within the front windshield. View "Simmons v. State" on Justia Law

The Supreme Court reversed the judgment of the district court denying Steven Mitchell's motion for a sentence reduction as untimely, holding that the district court erred in denying Mitchell's motion as untimely.Defendant pled no contest to one count of felony interference with custody. The district court sentenced Defendant to three and one-half years in prison. Defendant later filed a pro se Wyo. R. Crim. P. 35(b) motion for reduction of his sentence. The district court issued an order denying the motion as untimely. The Supreme Court reversed and remanded the case to the district court for a ruling on the merits, holding that the district court erred in denying the motion as untimely and that the error was not harmless. View "Mitchell v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court sentencing Defendant, after a remand, to an aggregate sentence of twelve to fifty years for aggravated robbery, to be served consecutively to a previously imposed sentence for first-degree murder, holding that Defendant's aggregate sentence was constitutional.When Defendant was seventeen years old he and a friend robbed and murdered a hitchhiker. Defendant pled guilty to first degree murder, felony murder, and aggravated robbery. Defendant was convicted to life without parole, which the court later converted to life with the possibility of parole after twenty-five years for murder plus twenty to fifty years for aggravated robbery. Defendant later filed a motion to correct an illegal sentence, arguing that his new aggregate sentence remained a de facto life sentence. The trial court denied the motion, but the Supreme Court remanded. On remand, the trial court resentenced Defendant to twelve to fifty years for aggravated robbery, to be served consecutively to the previously imposed sentence for murder. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it sentenced Defendant for aggravated robbery. View "Davis v. State" on Justia Law

The Supreme Court dismissed Defendant's appeal from the district court's dismissal of his pro se "Petition for Exoneration Based on Factual Innocence," holding that Defendant did not properly invoke the Supreme Court's jurisdiction.Defendant was convicted of three counts of sexual abuse of a minor in the second degree and one count of sexual abuse of a minor in the third degree. Defendant later filed his petition for exoneration under Wyo. Stat. Ann. 7-12-401 through -407. The district court dismissed the petition without prejudice, determining that the petition was statutorily noncompliant. Defendant appealed. The Supreme Court dismissed the appeal, holding that the dismissal of Defendant's petition was not a final, appealable order, and therefore, this Court lacked jurisdiction over Defendant's appeal. View "Woods v. State" on Justia Law

The Supreme Court dismissed Petitioner's appeal from an order of the district court dismissing Petitioner's petition seeking exoneration under the Post-Conviction Determination of Factual Innocence Act, Wyo. Stat. Ann. 7-12-401 through 407, holding that this Court lacked jurisdiction because the court's order dismissing Petitioner's petition was not a final appealable order.The district court dismissed Petitioner's petition as deficient under the Act. The Supreme Court affirmed, holding (1) the order dismissing Petitioner's Factual Innocence Act petition following initial review is not a final appealable order; and (2) therefore, this Court lacked jurisdiction over Petitioner's appeal. View "Uden v. State" on Justia Law