Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the district court's denial of Defendant's motion to suppress evidence obtained after a search of his camper, holding that the search warrant contained sufficient untainted evidence to establish probable cause to search the camper.Defendant was charged with possession with intent to deliver a controlled substance and possession of a controlled substance. Defendant filed a motion to suppress, challenging the reasonableness of a search on September 8, 2017 and the probable cause for search warrants issued on September 9, 2017 and September 12, 2017. The district court denied the motion to suppress, and Defendant entered a conditional guilty plea to possession of a controlled substance. The Supreme Court affirmed, holding (1) Defendant's guilty plea did not preserve a Franks argument; and (2) even assuming the law enforcement officer unconstitutionally searched the camper when he opened plastic covering to look through a window on September 8, the warrant affidavit established probable cause through evidence attributable to the officer's unchallenged look through another window. View "Workman v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained from the search of Defendant's vehicle, holding that the law enforcement officer did not violate Defendant's Fourth Amendment rights by detaining him for a drug-dog sniff of his vehicle.Defendant pleaded guilty to possession of more than three ounces of marijuana. Defendant verbally reserved the right to appeal the district court's denial of his motion to suppress. The Supreme Court affirmed the denial of Defendant's motion to suppress, holding (1) while conditional plea agreements are typically required, under the unique circumstances of this case this Court exercises its discretion to review the verbally-reserved issue; and (2) Defendant was not seized in violation of the Fourth Amendment when the officer stopped him for following another vehicle too closely, and Defendant had reasonable suspicion justifying detaining Defendant for a drug-dog sniff of the vehicle. View "Robinson v. State" on Justia Law

The Supreme Court reversed in part the district court's "Order on Petition for Revocation of Probation" and remanded the matter to the district court with instructions to award Appellant an additional 341 days of credit for time served, holding that Appellant should receive an additional 341 days of credit for time served.Appellant entered an unconditional guilty plea to one count of possession of a felony amount of methamphetamine. The district court revoked Appellant's initial probation and imposed a split sentence. Appellant subsequently spent time in jail and in residential treatment. After he completed residential treatment Appellant entered the probationary term of his split sentence. The probation was later revoked. The district court then entered the order at issue, revoking Appellant's probation and imposing a three to five-year sentence, with credit for 120 days served. The Supreme Court reversed in part, holding that Appellant should receive an additional 341 days of credit for time served, from the time the split sentence was imposed through the time he was released from residential treatment/custody. View "Hoback v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of attempted sexual abuse of a minor in the second degree, holding that errors in the jury instructions and any deficiencies in defense counsel's performance associated with the instructions were not prejudicial.Specifically, the Court held (1) the evidence presented at trial was sufficient to convict Defendant of attempted sexual abuse of a minor in the second degree; (2) the jury instructions on the elements of attempted sexual abuse of a minor in the second degree were incorrect; (3) it was unnecessary to discuss in detail whether defense counsel's performance in addressing the jury instructions was deficient; and (4) Defendant was not prejudiced by incorrect jury instructions and/or his counsel's deficient performance because the State presented overwhelming showing Defendant was guilty of the crime. View "Weston v. State" on Justia Law

The Supreme Court affirmed the order of the district court revoking Defendant's probation and imposing sentence, holding that the district court had authority to revoke Defendant's probation and did not abuse its discretion when it revoked Defendant's probation.On appeal, Defendant argued that the district court lacked the authority to revoke his probation because the probation violation did not occur during the probationary period, as required by Wyo. Stat. 7-13-305(c) and, even if the court had the authority, it abused its discretion because there was no evidence supporting a finding that Defendant violated the probation condition willfully. The Supreme Court affirmed, holding (1) the phrase "probation period" encompasses the time during which a sentence is suspended and the time during which probation is being served; and (2) the district court could reasonably infer from the facts that Defendant willfully violated the term of his probation. View "Sena v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of stalking, in violation of Wyo. Stat. Ann. 62-506(b) and (e)(I), holding that Defendant's First Amendment right to free speech was not violated when he was prosecuted for writing absence letters to the victim.Specifically, the Supreme Court held (1) Defendant's right to free speech under the First Amendment was not violated when the State prosecuted him under section 6-2-506 for sending obscene letters to the victim, and the evidence was sufficient to support the jury's conclusion that the letters were obscene under the ordinary meaning of that term; (2) the district court did not err in instructing the jury or by refusing Defendant's request for a special verdict form; (3) the State presented sufficient evidence to establish that Defendant harassed the victim; and (4) the district court did not abuse its discretion by admitting evidence that Defendant had been warned not to send unsolicited letters. View "Dugan v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of one count of felony theft, holding that the evidence was sufficient to support the conviction and that the court's order contained sufficient finding of a common scheme.Defendant renovated a home and used the materials separately purchased by homeowners as a reduction to his bid price. Defendant later took the materials to a retailer and, in two separate transactions, returned them for more than $1000. The district court convicted Defendant of one count of felony theft. On appeal, Defendant argued that the evidence was insufficient to establish that he intentionally stole the materials and that the district court erred when it failed explicitly to find that the items were stolen pursuant to a "common scheme or the same transaction" under Wyo. Stat. Ann. 6-3-410 when it aggregated the value of the stolen property. The Supreme Court affirmed, holding (1) there was sufficient evidence to support the conviction; and (2) the district court made the necessary finding of a common scheme, and its finding was not clearly erroneous. View "Gore v. State" on Justia Law

The Supreme Court affirmed Defendant's aggregate sentence that left him eligible for parole after serving thirty-five years, holding that Defendant failed to show a constitutional violation or an abuse of discretion in the district court's sentencing decision.Defendant was convicted of one count of first-degree murder and twelve counts of aggravated assault and battery for crimes he committed at age sixteen. The district court sentenced Defendant to an aggregate prison term that left him eligible for parole after fifty-two years. The Supreme Court reversed the sentence and remanded for resentencing, holding that the sentence violated the Eighth Amendment because it was a de facto life without parole sentence. On remand, the district court imposed an aggregate sentence that left Defendant eligible for parole after serving thirty-five years. The Supreme Court affirmed, holding that Defendant's sentence did not violate the Eighth Amendment and that the district court did not abuse its discretion in sentencing Defendant. View "Sam v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of sexual assault in the third degree and intentional abuse of a vulnerable adult, holding that there was no error in the proceedings below.On appeal, Defendant argued that the district court erred when it admitted hearsay testimony of five witnesses and a video recording of the victim's Children Advocacy Project (CAP). Defendant also argued that the evidence was insufficient for the jury to convict him of the offenses. The Supreme Court affirmed, holding (1) neither the admission of the challenged testimony nor the CAP interview video violated a clear and unequivocal rule of law in a clear and obvious way, and in any event, Defendant failed to meet his burden of proving that he was materially prejudiced by admission of the evidence; and (2) the evidence was sufficient for the jury to convict Defendant of both sexual assault in the third degree and intentional abuse of a vulnerable adult. View "Brown v. State" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motions to withdraw his no contest plea to driving under the influence of alcohol, holding that Defendant's no contest plea was not knowing or voluntary, and therefore, the district court abused its discretion in denying Defendant's motions to withdraw his plea.On appeal, Defendant argued that his plea was not knowing or voluntary because the totality of the circumstances showed he did not fully understand the amended charge, the plea agreement, or the consequences of his plea. Further, Defendant claimed that he had insufficient time to speak with his attorney to discuss these matters prior to pleading guilty. The Supreme Court agreed, holding (1) under the specific circumstances of this case, Defendant's plea was not knowing or voluntary; and (2) the district court abused its discretion in not allowing Defendant to withdraw his no contest plea. View "Steffey v. State" on Justia Law