Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of aggravated assault and battery and mandatory life sentence, holding that the district court did not err in denying Defendant's motion for a new trial based on ineffective assistance of counsel.In charging Defendant, the State sought a habitual criminal sentencing enhancement under Wyo. Stat. Ann. 6-10-201. After a trial, the jury convicted Defendant and found that he qualified for the habitual criminal enhancement under section 6-101-201(b)(ii). The court sentenced Defendant to life imprisonment. Defendant appealed, arguing that his trial counsel did not communicate with him in a manner that enabled him fully to understand he was facing a life sentence, and this deficiency fell below the standard of professional conduct. The Supreme Court affirmed, holding that Defendant failed to establish prejudice. View "Lewis v. State" on Justia Law

The Supreme Court reversed the judgment of the district court granting the State's motion to dismiss the charges against Defendant without prejudice, holding that the court abused its discretion in granting the State's Wyo. R. Crim. P. 48 motions.The State filed two separate informations charging Defendant with multiple felonies and misdemeanors. The State later filed motions to join the charges for trial. The district court denied the motions as untimely. Thereafter, the State filed a motion to dismiss the charges without prejudice, noting that it intended to refile the charges in a single information. The district court entered orders of dismissal without prejudice on the basis that the State had provided a reason for its motions. The Supreme Court reversed and remanded for entry of an order dismissing the charges with prejudice, holding that the district court abused its discretion in granting the State's Rule 48 motions where the State was attempting to use dismissal without prejudice to escape from a position of disadvantage caused by its failure diligently to prosecute the case. View "Carabajal v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for felony possession of marijuana, holding that Defendant was not prejudiced by the State's breach, if any, of the written plea agreement.In exchange for Defendant's guilty plea to possession of marijuana the State agreed to dismiss a misdemeanor possession of methamphetamine charge and recommend that the trial court suspend Defendant's sentence in favor of supervised probation. The State, however, reneged on its promise to recommend a suspended sentence at sentencing, claiming that it withdrew the plea agreement after the trial court had accepted Defendant's plea because Defendant violated the terms of his bond. The Supreme Court affirmed, holding that Defendant failed to show that he was prejudiced by the State's breach, if any. View "Grater v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for one count of sexual abuse of a minor in the second degree and one count of child endangerment, holding that the district court did not abuse its discretion when it did not evaluate taint sua sponte or when it denied Defendant's motion to continue trial, and the prosecutor did not commit prejudicial misconduct.Specifically, the Supreme Court held (1) the district court did not abuse its discretion when it did not evaluate taint during the competency hearing; (2) the district court did not abuse its discretion when it denied Defendant's motion to continue trial; (3) the prosecutor did not commit prejudicial misconduct; and (4) the district court did not err by denying Defendant's motion for a new trial based on ineffective assistance of counsel. View "Shields v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree sexual assault and incest for acts committed against KW, his eighteen-year-old stepdaughter, holding that the district court's error admitting evidence of uncharged misconduct which the State had not provided notice of and which had not been subject to a Wyo. R. Evid. 404(b) admissibility analysis was harmless.Specifically, the Supreme Court held that, as in Broberg v. State, 428 P.3d 167 (Wyo. 2018), the admission of the 404(b) evidence was error, but there was no reasonable probability that the verdict against Defendant would have been more favorable had the state's section 404(b) evidence not been admitted. View "Blanchard v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated assault and battery, holding that Defendant was not prejudiced by the admission of Wyo. R. Evid. 404(b) evidence without the required analysis under Gleason v. State, 57 P.3d 332 (Wyo. 2002).On appeal, Defendant argued that the district court abused its discretion by admitting evidence that Defendant had sexual intercourse with the complaining witness twice without her consent on the evening of the altercation. Specifically, Defendant argued that that the evidence was uncharged misconduct evidence subject to Rule 404(b) and that the trial court failed to conduct the required Gleason analysis before admitting the evidence. The Supreme Court held that Defendant was not prejudiced by admission of the sexual intercourse evidence and that there was no reasonable possibility the verdict would have been more favorable to Defendant had the sexual intercourse evidence been excluded. View "Vinson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of three counts of felony theft stemming from her use of two credit cards to purchase personal items and services, holding that sufficient evidence supported the convictions.Defendant, the chief operating officer and executive director of the Buffalo Chamber of Commerce, used two credit cards issued in the Chamber's name and approved to carry out the Chamber's business for personal purchases. A jury convicted Defendant of felony theft. On appeal, Defendant argued that her conduct was lawful because the Chamber authorized each personal purchase by voluntarily paying each credit card bill, and therefore, the evidence did not satisfy the statutory definition of "property." The Supreme Court affirmed, holding (1) the value of available credit on a credit card is intangible property subject to theft under Wyo. Stat. Ann. 6-3-402(a); and (2) sufficient evidence showed that Defendant exercised unauthorized control over the Chamber's property. View "Fox v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of first degree sexual abuse of a minor, holding that the district court did not err in allowing the State to withdraw from its plea agreement with Defendant and that Defendant was not denied the right to testify in his own defense.Pursuant to a plea agreement, Defendant agreed to plead no contest to third degree sexual abuse of a minor. The State subsequently filed a motion to withdraw from the plea agreement. After a hearing, the district court granted the motion. After a jury trial, Defendant was found guilty of first degree sexual abuse of a minor. The Supreme Court affirmed, holding (1) because the State withdraw from its plea agreement before Defendant acted on his promise to change his plea and Defendant did not otherwise assert that he detrimentally relied on the agreement before the State withdraw from it, the agreement wasn't to an enforceable contract, and the district court did not err in granting the State's motion to withdraw from it; and (2) Defendant did not assert a cognizable claim that his right to testify was denied. View "Nelson v. State" on Justia Law

The Supreme Court affirmed the district court's order of restitution awarding restitution to three victims, including Jerry Goodman, a victim whose insurance paid for the property destroyed by Defendant, holding that the district court properly ordered restitution to Goodman.Defendant pleaded guilty to one count of felony theft. The district court sentenced Defendant to a term of imprisonment and ordered Defendant to pay restitution to three victims, including $16,998 to Goodman, whose truck and trailer Defendant stole. On appeal, Defendant argued that the district court could not order restitution to Goodman because Goodman's insurance company paid him for the vehicle's full value and took title to the truck. The Supreme Court affirmed, holding that because the record contained no evidence of a subrogation right, or the lack thereof, the district court properly required Defendant to pay restitution to Goodman. View "Hudson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of strangulation of a household member and driving while under the influence, holding that the district court did not err in admitting a nurse's testimony under the hearsay exception for medical diagnosis and treatment and that the evidence was sufficient to support the conviction.On appeal, Defendant argued that the district court erred in admitting the testimony of a Sexual Assault Nurse Examiner (SANE nurse) under Wyo. R. Evid. 803(4) and that the evidence was insufficient to support his conviction for strangulation of a household member. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting the SANE nurse's statement under Rule 803(4); and (2) there was sufficient evidence to support the jury's guilty verdict on strangulation of a household member. View "Morones v. State" on Justia Law