Justia Criminal Law Opinion Summaries

The Supreme Court summarily affirmed the order of the district court denying Defendant's motion to enforce his claimed plea agreement, which the court treated as a Wyo. R. Crim. P. 35(a) motion, holding that Defendant's brief on appeal failed to comply with the Wyoming Rules of Appellate Procedure and contained no cogent argument or citation to pertinent authority.In exchange for Defendant's guilty plea, the State agreed that it would not seek the death penalty. The district court sentenced Defendant to life imprisonment. In his motion to enforce his claimed plea agreement, Defendant did no more than state his belief that he should have been required to serve no more than seven to eight years in prison for the first degree murder and reference a previously submitted commutation request. The Supreme Court summarily affirmed the district court order denying Defendant's motion, holding that Defendant's brief failed in all respects to comply with the rules of appellate procedure. View "Harrison v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree felony murder and aggravated child abuse but remanded to correct a sentencing error, holding that the district court did not err in denying Defendant's request for two lesser-included offense instructions and that prosecutorial misconduct did not require a new trial.On appeal, Defendant argued that the district court erred in denying his lesser-included offense instructions and that the prosecutor's statements during closing arguments constituted prosecutorial misconduct. The Supreme Court affirmed, holding that the district court did not err in denying Defendant's request for the lesser-included offense instructions and that the prosecutor did not commit misconduct. The Court, however, remanded the case to correct a sentencing error brought to its attention by the State. View "Hartley v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence seized from his home, holding that the district court did not err when it concluded that the warrantless search of Defendant's home was constitutional under the emergency aid exception to the Fourth Amendment's warrant requirement.After the district court denied his suppression motion, Defendant entered a conditional guilty plea to various drug crimes, including possession of marijuana with intent to deliver, possession of methamphetamine, and possession of marijuana. Defendant appealed the denial of his motion to suppress. The Supreme Court affirmed, holding that intrusion into Defendant's home was lawful and justified by the emergency aid exception to the Fourth Amendment's warrant requirement. View "Ferch v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of intimidating and influencing a witness in violation of Wyo. Stat. Ann. 6-5-305(a), holding that Defendant did not show that the prosecutor's comments in rebuttal closing argument or the district court's failure to instruct the jury on voluntariness constituted plain error.Specifically, the Court held (1) the prosecutor did not commit plain error during rebuttal closing argument by improperly shifting the burden of proof to Defendant or stating facts not in evidence; and (2) the district court did not plainly err in failing to instruct the jury that it had to find Defendant acted voluntarily. View "Black v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of misdemeanor interference with a peace officer, holding that Defendant's actions were sufficient to constitute interference with a peace officer and that the circuit court did not err in refusing to give Defendant's proposed jury instruction.Specifically, the Supreme Court held (1) the jury was presented with sufficient evidence to find Defendant guilty of misdemeanor interference with a peace officer; and (2) the circuit court did not err in rejecting Defendant's proposed jury instruction concerning the type of verbal conduct that may constitute interference with a peace officer. View "Garza v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of two counts of sexual intrusion on a victim under Wyo. Stat. Ann. 6-2-314(a)(i), holding that the district court did not err when it admitted testimony under Wyo. R. Evid. 404(b) and 801(d)(1)(B) and did not violate Defendant's rights under the Confrontation Clause when it allowed the State to amend the felony information after the State had presented its witnesses.Specifically, the Supreme Court held (1) the district court did not abuse its discretion in admitting evidence of other acts under Rule 404(b) or in allowing the victim's prior consistent statements under Rule 801(d)(1)(B); and (2) the amendment to the felony information without a continuance did not deny Defendant his right to effectively cross-examine the witnesses or prejudice his defense. View "LaJeunesse v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony possession of marijuana, holding that the State's trial evidence was sufficient to establish that Defendant possessed the marijuana.Defendant was convicted of violating Wyo. Stat. Ann. 35-7-1031(c)(iii), which makes it a felony for a person to knowingly or intentionally have in his possession more than three ounces of marijuana in plant form. On appeal, Defendant argued that the State did not prove he exercised dominion and control over the marijuana. The Supreme Court affirmed, holding that the trial evidence was clearly sufficient to support the jury's conclusion that Defendant constructively possessed more than three ounces of marijuana. View "Huckins v. State" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of two counts of possession with intent to deliver a controlled substance and one count of interference with a peace officer, holding that Defendant's trial counsel provided ineffective assistance by failing to challenge the extension of Defendant's traffic stop.The traffic stop in this case led to the discovery of drugs and drug paraphernalia in Defendant's vehicle. Defendant filed a motion to suppress, arguing that the initial stop was not supported by reasonable suspicion. The district court denied the motion. On appeal, Defendant argued, among other things, that his trial counsel provided ineffective assistance by failing to challenge the duration of the traffic stop in his motion to suppress. The Supreme Court reversed and remanded the case, holding (1) Wyo. R. Crim. P. 12(b) precluded plain error review of the issues not raised in Defendant's motion to suppress evidence; and (2) Defendant showed a reasonable probability that, but for counsel's failure to challenge the duration of the stop and the actions of law enforcement officers during the stop, the outcome of the trial would have been different. View "Mills v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of three counts of second-degree sexual assault, holding that the district court did not plainly err in failing to instruct the jury that it had to fine beyond a reasonable doubt that Defendant acted voluntarily.On appeal, Defendant argued that because second-degree sexual assault is a general intent crime, it required a voluntary act, and therefore, the district court erred in failing to instruct the jury on the mens rea element of second-degree sexual assault. The Supreme Court affirmed, holding that no instruction on voluntariness was required where Defendant did not show she was prejudiced by any alleged failure to provide a voluntariness instruction to the jury and Defendant did not present any evidence suggesting her actions were not voluntary. View "Wyant v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of possession with intent to deliver marijuana, holding that the State's evidence at trial was sufficient to prove Defendant constructively possessed the marijuana.A jury found Defendant guilty of possession with intent to deliver marijuana in violation of Wyo. Stat. Ann. 35-7-1031(a)(ii). The district court sentenced Defendant to a term of incarceration of four to nine years, sentence suspended. On appeal, Defendant argued that the State failed to prove he possessed the marijuana. The Supreme Court affirmed, holding that the State's evidence was clearly sufficient to establish that Defendant had constructive possession of the marijuana. View "Pyles v. State" on Justia Law