Justia Criminal Law Opinion Summaries

The Supreme Court remanded this case for a new hearing under Batson v. Kentucky, 476 U.S. 79 (1986), holding that the district court clearly erred by allowing the State to exercise a peremptory challenge to exclude an African American from the jury. The record supported the validity of only one of the prosecutor’s race-neutral reasons for his peremptory challenge and did not show that the district court would credit this reason alone. Specifically, one of the prosecutor’s two explanations for the peremptory challenge upon which the district court relied failed, and the record did not show that the district court would find that the prosecutor was motivated solely by the valid grounds. Therefore, the case must be remanded for a new Batson hearing in which the district court must reassess the prosecutor’s credibility in light of the discrepancy between the record and his explanation. View "Roberts v. State" on Justia Law

The Supreme Court remanded this case for a new hearing under Batson v. Kentucky, 476 U.S. 79 (1986), holding that the district court clearly erred by allowing the State to exercise a peremptory challenge to exclude an African American from the jury. The record supported the validity of only one of the prosecutor’s race-neutral reasons for his peremptory challenge and did not show that the district court would credit this reason alone. Specifically, one of the prosecutor’s two explanations for the peremptory challenge upon which the district court relied failed, and the record did not show that the district court would find that the prosecutor was motivated solely by the valid grounds. Therefore, the case must be remanded for a new Batson hearing in which the district court must reassess the prosecutor’s credibility in light of the discrepancy between the record and his explanation. View "Roberts v. State" on Justia Law

The Supreme Court affirmed the sentences imposed in connection with Defendant’s convictions of one count of conspiracy to deliver methamphetamine and one count of possession of marijuana with intent to deliver, holding that the district court’s denial of Defendant’s motion for a continuance did not deprive her of the opportunity to obtain and present evidence in mitigation of her sentence.After Defendant pleaded guilty of the offenses, she sought and obtained a continuance of the sentencing hearing. Defendant sought a second continuance shortly before the rescheduled hearing. The district court denied the motion. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant’s motion under the circumstances of this case. View "Steinfeldt v. State" on Justia Law

The Supreme Court reversed Defendant’s conviction of aggravated assault and attempted second-degree murder for stabbing her uncle, holding that the district court erred in declining to give the defense’s proposed instruction regarding the duty to retreat in one’s residence.Based upon its conclusion that Defendant was not a resident of her uncle’s home, the district court declined to give Defendant’s proposed castle doctrine instruction to the jury. The Supreme Court held that the district court improperly resolved the disputed factual question of whether Defendant was a resident of her uncle’s home because the question of Defendant’s residence was a factual one. Therefore, the question should have been submitted to the jury. If the jury determined the home to be Defendant’s residence, the district court should have instructed the jury regarding the castle doctrine. Further, the district court erred when it gave an incorrect malice definition and abused its discretion when it prohibited testimony of specific instances of conduct relating to the victim’s character for violence. View "Widdison v. State" on Justia Law

The Supreme Court reversed Defendant’s conviction of aggravated assault and attempted second-degree murder for stabbing her uncle, holding that the district court erred in declining to give the defense’s proposed instruction regarding the duty to retreat in one’s residence.Based upon its conclusion that Defendant was not a resident of her uncle’s home, the district court declined to give Defendant’s proposed castle doctrine instruction to the jury. The Supreme Court held that the district court improperly resolved the disputed factual question of whether Defendant was a resident of her uncle’s home because the question of Defendant’s residence was a factual one. Therefore, the question should have been submitted to the jury. If the jury determined the home to be Defendant’s residence, the district court should have instructed the jury regarding the castle doctrine. Further, the district court erred when it gave an incorrect malice definition and abused its discretion when it prohibited testimony of specific instances of conduct relating to the victim’s character for violence. View "Widdison v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree murder, entered after a jury trial. On appeal, Defendant argued that the district court erred in several ways instructing the jury and that the court utilized an improper stepped verdict form. The Supreme Court disagreed, holding (1) any error or confusion that may have existed in the jury instructions regarding the law of self defense could not have prejudiced Defendant; (2) Defendant failed to demonstrate plain error in the district court’s jury instructions regarding the State’s burden of proof regarding a “sudden heat of passion” in voluntary manslaughter; (3) there was no plain error in the verdict form the district court submitted to the jury; and (4) the district court did not commit plain error when it did not provide the jury a definition of “recklessly” or “enhanced recklessness” within the instruction defining malice in second-degree murder. View "Johns v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant’s pro se motion to correct an illegal sentence pursuant to Wyo. R. Crim. P. 35(a), holding (1) res judicata did not bar Defendant’s Rule 35(a) double jeopardy claim; and (2) the district court properly denied Defendant’s actual innocence and constructive denial of counsel claims on the basis that such claims are not cognizable under Rule 35(a).Defendant pleaded guilty to one count of third degree sexual assault and one count of abuse of a vulnerable adult. Defendant was sentenced to consecutive prison terms. Defendant later filed a motion to correct an illegal sentence. The district court denied the motion. The Supreme Court affirmed, holding (1) because Defendant did not show good cause for failing to raise his double jeopardy claim in earlier proceedings, his claim was barred by res judicata; and (2) Defendant’s remaining claims were not cognizable under a Rule 35(a) motion. View "Hicks 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 of a minor and one count of first degree sexual assault of a minor. The court held (1) the district court did not abuse its discretion in admitting uncharged acts evidence under Wyo. R. Evid. 404(b); and (2) the trial court did not abuse its discretion in applying the rape shield statute to prohibit Defendant from cross-examining one of the victims on her status as a victim in a prior sexual abuse case. View "Moser 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 of a minor and one count of first degree sexual assault of a minor. The court held (1) the district court did not abuse its discretion in admitting uncharged acts evidence under Wyo. R. Evid. 404(b); and (2) the trial court did not abuse its discretion in applying the rape shield statute to prohibit Defendant from cross-examining one of the victims on her status as a victim in a prior sexual abuse case. View "Moser v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant’s motion to suppress evidence obtained as a result of a detention and subsequent search of his vehicle.Defendant was charged with one count of possession of a controlled substance and one count of a controlled substance with intent to deliver. Defendant moved to suppress evidence based on the roadside search of his car, arguing that the initial traffic stop was not justified by reasonable suspicion and that the subsequent detention was unconstitutional. The district court denied the motion to suppress. On appeal, Defendant conceded that the initial stop was justified but challenged the investigative detention. The Supreme Court affirmed, holding that the trial court did not err in denying Defendant’s motion to suppress. View "Harris v. State" on Justia Law