Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant’s conviction of one count of first degree sexual assault of minor, holding that the district court erred in providing an ex parte response to a juror’s note, but the error was harmless, and that Defendant received effective assistance of counsel.Specifically, the Court held (1) the district court erred when it responded to a juror note expressing confusion over DNA testimony without informing either party of the juror note and the court’s response to it, but the error was harmless; and (2) Defendant did not receive ineffective assistance of counsel based on an alleged conflict or interest or on counsel’s purported failure to adequately pursue a theory of intentional secondary DNA transfer. View "Wall v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of felony possession of a controlled substance, holding that the district court did not err in denying Defendant's motion to suppress evidence obtained during a law enforcement officer’s search of Defendant’s vehicle.Defendant entered a conditional no contest plea to possession of a controlled substance. On appeal, Defendant argued that the district court erred in failing to suppress evidence obtained during what he characterized as an unreasonable search. The Supreme Court affirmed, holding (1) Defendant waived his right to argue on appeal that the officer conducted an unlawful search when he leaned through the passenger window of the car and smelled marijuana; and (2) under the totality of the circumstances, the officers’ actions were objectively reasonable, and the search did not violate Defendant’s Fourth Amendment rights. View "Ray v. State" on Justia Law

The Supreme Court affirmed the district court’s judgment finding Defendant’s guilty of sexual abuse of a minor in the first and second degree, holding that there was sufficient evidence to sustain the conditions and that the district court did not err when it denied the admission of character evidence of the alleged victim.Specifically, the Supreme Court held (1) the district court did not err when it denied Defendant’s motion for judgment of acquittal on both counts; and (2) the district court did not err when it precluded Defendant from presenting character evidence pertaining to the alleged victim on the grounds that it was inadmissible. View "Martinez v. State" on Justia Law

The Supreme Court affirmed the order of the district court affirming the forfeiture of Scott Alan Addison’s $50,000 cash bond after Addison died prior to his criminal trial while subject to warrant for his arrest for violation of his bond conditions, holding that the doctrine of abatement ab initio did not apply to the bond forfeiture proceeding.Scott’s daughter, Kelly Addison, appealed the order affirming the forfeiture of Scott’s cash bond, arguing that the common law doctrine of abatement ab initio applied. The Supreme Court disagreed, holding that where Scott died prior to trial, leaving no judgment of conviction or proceedings under a judgment of conviction for the court to abate and where the bond forfeiture proceeding was a collateral proceeding unrelated to any final determination of Scott’s guilt or punishment, the doctrine of ab initio did not apply. View "Addison v. Albany County" on Justia Law

The Supreme Court affirmed an order of the district court denying Appellant’s motion for sentence reduction, holding that the district court did not abuse its discretion when it denied Appellant’s motion for sentence reduction.Appellant, an addicted offender, failed on two separate occasions to complete treatment programs, resulting in his incarceration. While incarcerated, Appellant successfully completed treatment. Appellant moved for a reduction in sentence under Wyo. R. Crim. P. 35(b). The district court denied the motion. The Supreme Court affirmed, holding (1) the Addicted Offender Accountability Act does not require the release of an offender who completes treatment while incarcerated; and (2) the district court did not abuse its discretion or violate the AOAA when it denied Appellant’s motion for sentence reduction after he successfully completed various treatment programs during his incarceration. View "Cooper v. State" on Justia Law

The Supreme Court reversed Defendant’s conviction of fourth offense felony driving while under the influence (DWUI), holding that the district court erred, as a matter of law, when it concluded that the loopback for a fourth offense DWUI is to the date of the conviction and not to the date of the underlying offense.The State charged Defendant with felony DWUI in violation of Wyo. Stat. Ann. 31-5-233(b) and (e). The State based Defendant’s felony charge on his three prior convictions for DWUI within ten years of his most recent arrest. Defendant’s first offense did not occur within ten years of his fourth, but his conviction for the first for the first offense occurred within ten years of his fourth offense. Defendant appealed after pleading guilty to fourth offense felony DWUI. The Supreme Court reversed, holding that the felony enhancement loopback is to the offense and not the conviction. View "Rhoads v. State" on Justia Law

The Supreme Court affirmed the decision of the district court allowing the State to present testimony about an altercation Defendant had in jail while awaiting trial on charges of aggravated child abuse, holding that the district court abused its discretion in admitting the evidence but that Defendant was not prejudiced by the error.After a jury trial, Defendant was found guilty aggravated child abuse. Defendant appealed, arguing that the district court abused its discretion when it admitted evidence of the jail incident under Wyo. R. Evid. 404(b). The Supreme Court affirmed, holding (1) the admission of the evidence violated Rule 404(b); but (2) there was no reasonably probability that the verdict would have been different if the jail incident had not been admitted into evidence. View "Swett v. State" on Justia Law

The Supreme Court affirmed the decision of the district court denying Defendant’s motion to suppress her statements to highway patrol troopers and the marijuana they subsequently found in her car, holding that the record supported the district court’s finding that Defendant’s statements to the troopers were not coerced and the conclusion that the troopers did not violate Defendant’s due process rights.Defendant was the passenger in a car that was stopped for speeding. In response to questioning by the troopers, Defendant admitted to possessing medical marijuana that was located in the back of the car. After a search, the the troopers discovered marijuana. The Supreme Court affirmed, holding (1) the troopers’ detention and questioning of Defendant after the traffic stop was not unreasonable under the circumstances; and (2) Defendant gave her statements to the troopers voluntarily and and without coercion. View "Rodriguez v. State" on Justia Law

Defendant’s conviction of felony possession of marijuana, holding that Defendant did not demonstrate plain error when a supervisor from the state crime lab testified in place of the lab analyst who tested and weighed the marijuana.On appeal, Defendant argued that the State’s admission of the lab report containing the lab analyst’s conclusions violated his right to confrontation because the supervisor testified in place of the analyst. The Supreme Court affirmed without addressing the confrontation issues, holding that, even if the admission violated the confrontation clause, Defendant was not prejudiced. View "Lewis v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of first-degree felony murder and sentence of life imprisonment, holding that Defendant failed to demonstrate plain error in testimony elicited from medical experts concerning a diagnosis that has a distinct legal meaning.On appeal, Defendant argued that the State’s medical experts offered improper testimony as to Defendant’s guilt or credibility. The Supreme Court disagreed, holding (1) the district court did not err in permitting the challenged testimony because the diagnoses contained terms with distinct legal meanings that did not equate to expressing an opinion as to Defendant’s guilt; (2) Defendant did not demonstrate plain error in testimony elicited from medical experts concerning inconsistencies between Defendant’s proposed mechanism of injury and their observations of the victim’s injuries; and (3) Defendant did not demonstrate plain error in the State’s cross-examination of a certified forensic pathologist. View "Nielsen v. State" on Justia Law