Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant’s conviction of one count of third-degree sexual assault, holding that Defendant was not denied her right to due process of law under the Fifth and Fourteenth Amendments to the United States Constitution or under Wyo. Const. art. I, 6,7, and 36.On appeal, Defendant argued, inter alia, that Wyo. Stat. Ann. 6-2-304(a)(iii) and 6-2-303(a)(vii) were facially invalid because they were facially overbroad. The Supreme Court affirmed, holding (1) the statutes at issue are not facially overbroad in violation of the Fourteenth Amendment; and (2) the statutes at issue are not overly broad in violation of Wyo. Const. art. I, 6, 7, and 36. View "Sheesley v. State" on Justia Law

The Supreme Court affirmed the district court’s denial of Appellant’s petition for post-conviction relief, holding that res judicata barred Appellant’s claims.In his petition for post-conviction relief, Appellant challenged the same convictions and sentences he challenged in an earlier motion to correct an illegal sentence, and on the same grounds - double jeopardy. The district court found that Appellant’s claims were barred by res judicata. The Supreme Court affirmed, holding that Appellant failed to present the Court with good cause to avoid an application of the doctrine of res judicata under the facts of this case, and therefore, Appellant’s claims were appropriately barred. View "Goetzel v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of delivery of a controlled substance, holding that Defendant’s failure to file a pretrial motion to suppress identification evidence precluded this Court’s review of Defendant’s due process claim.On appeal, Defendant argued that his right to due process was violated when the district court admitted into evidence a witness identification that was based on a single photo, rather than a photo array. The Supreme Court affirmed the judgment, holding (1) a defendant’s failure to assert an objection or defense through a pretrial motion required by Wyo. R. Crim. P. 12(b)(3) is a bar to appellate review of a due process claim unless good cause is shown for the defendant’s failure to make the required finding; and (2) because Defendant did not file required motion to suppress the identification evidence against him required by Rule 12(b)(3) and did not show good cause for that failure, Defendant waived appellate review of his claim. View "Rodriguez v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for driving under the influence (DWUI) - fourth offense in ten years, holding that the charging document (Information) plainly charged Defendant with a fourth offense felony DWUI, thereby invoking the district court’s subject matter jurisdiction.On appeal, Defendant argued that the Information failed to state a felony offense because it did not allege three prior offenses resulting in convictions within the ten-year loopback period required by statute. The Supreme Court affirmed, holding (1) any mistake in alleging if or when Defendant’s prior offenses occurred did not constitute a jurisdictional defect; and (2) by entering an unconditional guilty plea, Defendant waived his challenge to the sufficiency of the Information. View "Protz v. State" on Justia Law

The Supreme Court reversed Appellant's convictions, holding that the record did not show a factual basis for Appellant's guilty plea as to counts two through eleven, and therefore, Appellant was prejudiced by her trial counsel’s deficient performance in advising her to plead guilty to ten felony counts under Wyo. Stat. Ann. 42-4-111(a) without a factual basis to satisfy the felony threshold.Appellant pled guilty to one felony count of Medicaid fraud related to improper record-keeping, ten felony counts of Medicaid fraud for making false or misleading statements in Medicaid claims when the value of the medical assistance is $500 or more, and two counts of felony forgery. Appellant filed a Wyo. R. App. P. 21(a) motion to withdraw her pleas due to ineffective assistance, arguing that the State unlawfully charged her with counts two through eleven and that her trial counsel provided ineffective assistance because he did not challenge those charges. Instead, trial counsel advised Appellant to accept a plea agreement under which Appellant pled guilty to all charges. The Supreme Court reversed, holding that there was no factual basis for Appellant’s guilty plea as to the ten felony counts, and trial counsel provided ineffective assistance by advising Appellant to accept the plea agreement. View "Mellott v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of two counts of second-degree sexual assault, holding that the district court did not err or abuse its discretion.Defendant, an OB/GYN, was convicted of sexually assaulting two of his patients. On appeal, Defendant argued that there was insufficient evidence to support his convictions, that the district court erred when it denied his proposed theory of defense instruction, and that the court erred when it denied his motion for arrest of judgment. The Supreme Court affirmed, holding (1) the State presented sufficient evidence that Defendant was in a position of authority; (2) the district court did not err when it rejected Defendant’s proposed theory of defense instruction; and (3) the district court did not abuse its discretion in denying Defendant’s post-trial Wyo. R. Crim. P. 34 motion for arrest of judgment. View "Harnetty v. State" on Justia Law

The Supreme Court affirmed the decision of the Office of Administrative Hearings (OAH) to uphold the suspension of Appellant’s driver’s license, holding that collateral estoppel did not bar the OAH from considering Appellants’ blood alcohol content (BAC) test results in the license suspension proceeding.In the companion criminal case, the municipal court dismissed Appellant’s criminal charges without prejudice without referring to the prosecution’s argument that a gap in the chain of custody of Appellant’s blood samples rendered the BAC test results inadmissible. On appeal from the OAH proceedings, Appellant argued that the OAH was collaterally estopped from considering the BAC test results in the license suspension proceeding. The Supreme Court disagreed, holding that all four collateral estoppel requirements were not met under the circumstances. View "Casiano v. State ex rel. Wyoming Department of Transportation" on Justia Law

The Supreme Court affirmed the district court’s order revoking Defendant’s probation and imposing the original suspended sentence, holding that the district court did not abuse its discretion by revoking Defendant’s probation.During the adjudicatory stage of proceedings the district court concluded that Defendant had failed to prove that he had complied the conditions of his probation and found that Defendant’s alleged violations were willful. The district court then revoked Defendant’s probation. The Supreme Court affirmed, holding (1) the scope of Defendant’s appellate waiver did not include his right to appeal from the order revoking his probation; and (2) the district court did not err in its conclusions, and the court’s findings were supported by the evidence. View "Bazzle v. State" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s Wyo. R. Crim. P. 35(b) motion for sentence reduction, holding that there was no abuse of discretion.Defendant received a sentence of fourteen to eighteen years in prison in connection with his conviction of one count of aggravated vehicular homicide. After the district court denied Defendant’s motion for sentence reduction Defendant appealed. The Supreme Court affirmed, holding (1) the district court had a rational basis for denying Defendant’s motion for sentence reduction; and (2) Defendant’s argument that his sentence was illegal because it violated the Eighth Amendment prohibition against cruel and unusual punishment was procedurally barred. View "Barrowes v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of three controlled substance charges, holding that the district court did not err by denying Defendant’s motion to suppress evidence discovered during a search of Defendant’s vehicle.On appeal, Defendant argued that a law enforcement officer violated his rights under the Fourth Amendment when he detained Defendant for a dog sniff and searched Defendant’s pickup truck without a warrant. The Supreme Court disagreed, holding (1) the officer’s initial stop of Defendant was justified because he was speeding; (2) the officer had reasonable, articulable suspicion that Defendant was engaged in drug crimes, justifying his further detention; and (3) the automobile exception to the warrant requirement applied to Defendant’s pickup. View "Pier v. State" on Justia Law