Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the district court’s entry of an order nunc pro tunc correcting two judgments entered against Defendant in 1998. The Court held (1) the district court had jurisdiction to enter the order nunc pro tunc irrespective of whether the Department of Corrections had standing to challenge the erroneous judgments; (2) there was no merit in Appellant’s claim that the Department of Corrections was required to seek reimbursement pursuant to Wyo. Stat. Ann. 7-6-108; and (3) as to Defendant’s remaining issues on appeal, he provided no cogent argument or pertinent authority to support either of his claims, and therefore, this Court will not consider them. View "Heinemann v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for second-degree murder, holding that, although the district court erred in some respects in instructing the jury, Defendant was not prejudiced by the errors. The Supreme Court held (1) the district court erred when it instructed the jury that Defendant had an absolute duty to retreat before using deadly force, but Defendant was not prejudiced by the instruction; (2) the district court did not violate a clear and unequivocal rule of law in instructing the jury on the mens rea element of second-degree murder; and (3) Defendant was not prejudiced when the district court failed to inform the jury that the State had the burden of proving that Defendant did not act in a sudden heat of passion in order to convict him of second-degree manslaughter. View "Sindelar v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for second-degree murder, holding that, although the district court erred in some respects in instructing the jury, Defendant was not prejudiced by the errors. The Supreme Court held (1) the district court erred when it instructed the jury that Defendant had an absolute duty to retreat before using deadly force, but Defendant was not prejudiced by the instruction; (2) the district court did not violate a clear and unequivocal rule of law in instructing the jury on the mens rea element of second-degree murder; and (3) Defendant was not prejudiced when the district court failed to inform the jury that the State had the burden of proving that Defendant did not act in a sudden heat of passion in order to convict him of second-degree manslaughter. View "Sindelar v. State" on Justia Law

The Supreme Court reversed Defendant’s convictions for driving under the influence causing serious bodily injury, holding that Defendant’s conditional no contest plea to the charge was not proper. Because Defendant did not present a proper cognitional plea, reversal of the district court’s order was required because “the issues are clearly controlled by settled Wyoming law.” Therefore, the Court entered an abbreviated opinion pursuant to Wyo. R. App. P. 9.06 and remanded the case to the district court for proceedings consistent with this opinion. View "Hardman v. State" on Justia Law

The Supreme Court reversed Defendant’s convictions for driving under the influence causing serious bodily injury, holding that Defendant’s conditional no contest plea to the charge was not proper. Because Defendant did not present a proper cognitional plea, reversal of the district court’s order was required because “the issues are clearly controlled by settled Wyoming law.” Therefore, the Court entered an abbreviated opinion pursuant to Wyo. R. App. P. 9.06 and remanded the case to the district court for proceedings consistent with this opinion. View "Hardman 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 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