Justia Criminal Law Opinion Summaries

Joseph W. Russell entered a conditional guilty plea to possession of methamphetamine, reserving his right to appeal the constitutionality of a warrantless search conducted as he entered the Uinta County Courthouse. The search, performed by Deputy Dan Jensen, involved a magnetometer alerting to metal in Russell's waist area, leading to a pat-down and the discovery of a snus can containing methamphetamine. Russell was charged with felony possession of a controlled substance.The district court denied Russell's motion to suppress the evidence, finding the search reasonable under the Fourth Amendment. Russell entered a conditional guilty plea, allowing him to appeal the suppression order. He was sentenced to one to three years of imprisonment, suspended in favor of two years of supervised probation. Russell timely appealed the denial of his motion to suppress.The Wyoming Supreme Court reviewed the case, focusing on whether the search violated the Fourth Amendment. The court applied a three-part test to determine the reasonableness of the search: the nature and immediacy of the governmental concern, the efficacy of the search in addressing that concern, and the nature of the privacy interest upon which the search intrudes. The court found that courthouse security is a compelling governmental interest, the use of a magnetometer and follow-up searches are effective in addressing this concern, and the privacy interest in the snus can was minimal given the context of courthouse security.The court concluded that the search was reasonable and affirmed the district court's denial of Russell's motion to suppress. The holding emphasized that the search was justified under the special needs exception to the Fourth Amendment, balancing the government's interest in courthouse security against the minimal intrusion on Russell's privacy. View "Russell v. State" on Justia Law

Matthew Justin Olson was convicted by a jury of conspiracy to commit first-degree murder. Olson was incarcerated in the Platte County Detention Center on federal charges and had pending state charges for domestic violence against his ex-wife, SK, who was a key witness. Olson asked his cellmate, Danny Hendershott, to kill SK in exchange for a government stimulus check. Hendershott initially agreed but later reported the plot to law enforcement, leading to an undercover operation by the ATF. Olson was subsequently charged with conspiracy to commit first-degree murder.The District Court of Uinta County allowed the State to introduce evidence under Rule 404(b) of the Wyoming Rules of Evidence, indicating Olson had other serious charges pending. Olson objected, arguing this evidence was prejudicial. The court limited the State to stating Olson had four serious charges pending and SK was an important witness. Olson was found guilty and sentenced to life imprisonment. He appealed, claiming the district court erred in its pretrial ruling on the admissibility of the 404(b) evidence.The Supreme Court of Wyoming reviewed the case and found that the word "serious" was never actually introduced during the trial. The State's evidence was limited to stating Olson had pending charges without categorizing them as serious. The court held that Olson's substantial rights were not affected by the district court's pretrial ruling since the evidence presented at trial was in line with what Olson deemed appropriate. Consequently, any potential error in the pretrial ruling was deemed harmless. The Supreme Court of Wyoming affirmed Olson's conviction. View "Olson v. State" on Justia Law

Everett Bray was convicted of felony stalking his ex-wife, MS, in violation of Wyoming Statute § 6-2-506(b)(iv) and (e)(iv). After being released from prison for a prior domestic violence offense against MS, Bray went to MS’s residence in June 2022, despite being warned by the sheriff’s department not to trespass. He threatened MS and her mother, leading to his arrest and a no-contact order. In January 2023, Bray returned to MS’s property, violating the protection order, and attempted to take her dog, resulting in another arrest.The District Court of Converse County sentenced Bray to 42-84 months in prison after a jury found him guilty of felony stalking. Bray appealed, arguing that the State presented insufficient evidence to prove he had the specific intent to harass MS.The Wyoming Supreme Court reviewed the case, applying the standard that assumes the State’s evidence is true and gives the State the benefit of every favorable inference. The court found that Bray’s actions, including his threats and repeated visits to MS’s property despite warnings and a protection order, demonstrated a continuity of purpose and intent to harass. The court held that a rational jury could find Bray’s conduct showed specific intent to harass MS, affirming the conviction. View "Bray v. The State of Wyoming" on Justia Law

Joseph Lyle Fredrick was charged with multiple counts of possession of controlled substances and misdemeanor theft in June 2021. He pled guilty to felony possession of marijuana and misdemeanor possession of heroin, leading to the dismissal of other charges. The district court sentenced him to 117 days for the misdemeanor, with credit for time served, and three to five years for the felony, suspended for three years of supervised probation. His probation was transferred to Oregon.In September 2023, the State filed a petition to revoke Fredrick’s probation, alleging he absconded and had no contact with his probation officer after July 2023. He was arrested in Oregon in November 2023, transported to Wyoming in December, and remained in custody. The district court held an initial appearance on December 19 and set an adjudication hearing for December 27. The State moved to allow the probation officer to testify by video, which the court granted. The hearing was continued to January 5, 2024, due to discovery issues and the probation officer’s failure to appear.At the January 5 hearing, the probation officer testified by video, and Fredrick moved to dismiss the revocation petition due to discovery violations. The court denied the motion but continued the hearing to January 19 to resolve the discovery dispute. On January 19, the court denied Fredrick’s motion to dismiss, found certain documents privileged, and concluded there was good cause for the continuances. The court revoked Fredrick’s probation and reinstated his three- to five-year sentence, with credit for time served.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court held that the district court did not abuse its discretion in extending the revocation hearing beyond the 15-day limit, allowing the probation officer to testify by video, and determining that certain probation records were privileged. The court also found that the discovery dispute did not warrant dismissal of the petition. View "Fredrick v. The State of Wyoming" on Justia Law

Donald Floyd Detimore was convicted of sexually abusing his step-granddaughter, MD, when she was between seven and nine years old. MD disclosed the abuse during a medical checkup at age sixteen, leading to an investigation where she detailed the abuse, including inappropriate touching and forced sexual acts. Detimore denied the allegations but admitted to behaviors that could be seen as inappropriate.The District Court of Fremont County denied Detimore's pretrial motion to introduce evidence under the rape shield statute, which he argued was crucial to his defense. This evidence pertained to an "embarrassing and shameful situation" involving MD, which Detimore claimed would show a motive for MD to fabricate the allegations. The court found the evidence's probative value did not substantially outweigh its prejudicial effect and thus excluded it. Detimore was subsequently found guilty by a jury and sentenced to 40-50 years in prison.The Wyoming Supreme Court reviewed the case and upheld the lower court's decision. The court found that the district court did not abuse its discretion in excluding the evidence under the rape shield statute, as Detimore failed to show a direct link between the "embarrassing and shameful situation" and MD's motive to lie. The court also determined that Detimore's constitutional rights to confront witnesses and present a complete defense were not violated, as he was able to challenge MD's credibility through other means during the trial. The Supreme Court affirmed the conviction and sentence. View "Detimore v. State" on Justia Law

Elijah Dante Dobbins was convicted by a jury of third-degree sexual abuse of a minor, strangulation of a household member, unlawful contact, and permitting a house party. The incident occurred during a party at Dobbins's apartment, where a physical altercation between Dobbins and his girlfriend, Harmony Lehmbeck, was recorded by a coworker. The videos showed various stages of the struggle, including moments where Dobbins appeared to choke Lehmbeck. Lehmbeck testified that Dobbins did not choke her and that she did not lose consciousness.The District Court of Natrona County admitted the videos as evidence during the trial. After the case was submitted to the jury, the court clarified which exhibits were admitted and stated that the videos would not be sent to the jury room but could be reviewed in the courtroom if requested. During deliberations, the jury asked to view the videos to clarify the alleged strangulation and battery. The court, with the approval of both parties, allowed the jury to view the videos twice under supervision.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision. The court held that the videos were non-testimonial, meaning the district court had broad discretion to allow the jury to review them during deliberations. The court found that the district court did not abuse its discretion by permitting the jury to view the videos again, given their short duration and the need for clarity on the strangulation charge. The court concluded that the district court's controlled procedure for reviewing the videos was appropriate and did not unduly emphasize the evidence. View "Dobbins v. State" on Justia Law

William R. Durkin, III, pled guilty to felony theft and felony property destruction and was sentenced to concurrent terms of five to eight years in prison, which were suspended in favor of a split sentence of one year in county jail followed by four to five years of supervised probation. After moving to Michigan, Durkin violated his probation by using alcohol and cocaine. As a sanction, Michigan Probation required him to complete the Tri County Community Adjudication Program (TRICAP), a probation residential center. Durkin spent 107 days at TRICAP but later violated probation again by drinking alcohol and absconding. Wyoming authorities filed a motion to revoke his probation, and Durkin was arrested in 2023.The District Court of Converse County revoked Durkin's probation and imposed his suspended prison sentences, reducing them to concurrent terms of four to six years. The court credited him for 413 days served in official detention in Wyoming but denied credit for the 107 days spent at TRICAP. Durkin appealed the revocation order and filed a motion to correct his sentences, arguing that the court erred by not crediting his time at TRICAP. The district court denied his motion, and Durkin appealed this decision as well.The Supreme Court of Wyoming reviewed the case and affirmed the district court's decision. The court held that Durkin was not in "official detention" while at TRICAP, as it was not an approved Wyoming Adult Community Corrections (ACC) program and did not subject him to escape charges under Wyoming law. Consequently, Durkin was not entitled to credit against his prison sentences for the time spent at TRICAP. The court concluded that the district court's sentences were legal and properly denied Durkin's motion to correct his sentences. View "Durkin v. The State of Wyoming" on Justia Law

In the early morning of July 8, 2022, Officer Luke Thorp of the Mills Police Department responded to a report of an unconscious male in a truck with syringes on the ground nearby. Upon arrival, Officer Thorp found Travis Dean Schaub in the vehicle, appearing disoriented and exhibiting signs of intoxication. After a slow and difficult exit from the vehicle, Schaub refused consent to a search, but Officer Thorp proceeded to search him, finding methamphetamine. Schaub was then handcuffed, placed in the patrol vehicle, and read his Miranda rights.The District Court of Natrona County reviewed Schaub’s motion to suppress the evidence obtained during the search, arguing it exceeded the scope of an investigatory stop and lacked a warrant. The State contended that the search was justified as incident to a lawful arrest for public intoxication. The district court agreed with the State, finding that Officer Thorp had probable cause to arrest Schaub for public intoxication under the Mills Municipal Code, and thus the search was lawful.The Supreme Court of Wyoming reviewed the case and affirmed the district court’s decision. The court held that Officer Thorp had probable cause to arrest Schaub based on his observed intoxication and the presence of syringes. The court further held that the search was valid as incident to a lawful arrest, even though it preceded the formal arrest by a few minutes. The court emphasized that the Fourth Amendment does not require the arrest to precede the search, as long as the arrest follows quickly and there is probable cause. Therefore, the denial of Schaub’s motion to suppress was upheld. View "Schaub v. The State of Wyoming" on Justia Law

On January 12, 2023, Officer Kevin Valentine of the Buffalo Police Department responded to a report of a suspicious vehicle at a gas station. The vehicle, a white Toyota Camry with Montana plates, had been parked at a pump for 30-45 minutes with its windows covered. Upon arrival, Officer Valentine observed Robert Labbe exiting the vehicle and asked him to return to the car for questioning. Labbe did not have his driver’s license, and a check revealed his license was suspended. The passenger, Elizabeth Davison, also had a suspended license and an active warrant.Officer Dustin Matthews arrived to assist, and after arresting Davison, the officers requested a canine unit. Deputy Quinn Maddox and his drug detection dog, Lucy, arrived 18 minutes later. Lucy alerted to the presence of drugs, leading to a search that uncovered marijuana, paraphernalia, and suspected fentanyl pills. The vehicle was towed for a more thorough search, revealing significant quantities of methamphetamine, fentanyl pills, marijuana, and THC. Labbe was charged with multiple counts of possession of controlled substances.Labbe filed a motion to suppress the evidence, arguing the drugs were found as a result of an illegal detention. The District Court of Johnson County denied the motion, stating the vehicle was in a public parking lot and law enforcement did not need reasonable suspicion, probable cause, or consent for a canine sniff. Labbe entered conditional guilty pleas to two felony counts, reserving the right to appeal the suppression ruling.The Wyoming Supreme Court affirmed the district court’s decision. The court held that the canine sniff was lawful as it occurred in a public place, and the dog’s alert provided probable cause for the search. The court found the evidence was not obtained as a result of an unlawful detention, making the search and subsequent seizure of drugs lawful. View "Labbe v. The State of Wyoming" on Justia Law

On March 4, 2023, Officer Brandon LaPointe stopped Antonio Kaye Lee's vehicle for illegally tinted windows. After confirming the tint violation, Officer LaPointe called for a canine unit, which alerted to narcotics. A search revealed methamphetamine and drug paraphernalia. When informed of his arrest, Mr. Lee resisted, leading to a struggle during which officers claimed he attempted to grab their firearms. Mr. Lee was charged with multiple offenses, including two counts of attempting to disarm a peace officer.The District Court of Sweetwater County presided over the trial. Mr. Lee admitted to the drug-related charges but denied attempting to disarm the officers, asserting he was merely trying to escape. The officers testified that Mr. Lee grabbed their firearms during the struggle. The jury found Mr. Lee guilty on all counts, and he was sentenced to concurrent prison terms for the misdemeanors and the attempted disarming charges.The Wyoming Supreme Court reviewed the case, focusing on whether the district court erred by not instructing the jury on all elements of attempting to disarm a peace officer, specifically the requirement of a "substantial step" toward committing the crime. The court found that the district court's failure to include this element in the jury instructions constituted plain error. The Supreme Court held that this omission materially prejudiced Mr. Lee because the jury might not have found he took a substantial step toward disarming the officers, given the conflicting testimonies. Consequently, the Wyoming Supreme Court reversed the district court's decision. View "Lee v. The State of Wyoming" on Justia Law