Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant’s conviction, rendered after a jury trial, of one count of domestic battery and one count of strangulation of a household member for attacking his girlfriend. On appeal, Defendant argued that the district court violated his constitutional right of confrontation when it refused testimony about the victim’s prior relationship from the sister of the victim’s former boyfriend. The Supreme Court disagreed, holding that the district court did not err by excluding the testimony under the rules of evidence and the court’s case law interpreting them. View "Garland v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of two counts of sexual abuse of a minor in the first degree and two counts of sexual abuse of a minor in the second degree. On appeal, Defendant argued that the district court erred in its instructions to the jury on the elements of the crime of sexual abuse of a minor in the first degree. In affirming, the Supreme Court held that the district court improperly instructed the jury on the two counts of sexual abuse of a minor in the first degree but that the errors did not prejudice Appellant. View "Nunamaker v. State" on Justia Law

Defendant was sixteen years old when he committed the crimes at issue in this case. The Supreme Court affirmed Defendant’s convictions of one count of first-degree murder, one count of aggravated assault and battery, and ten counts of attempted aggravated assault and battery but reversed Defendant’s sentence and remanded for resentencing. The court held (1) the district court did not abuse its discretion when it denied Defendant’s motion to transfer the proceedings to juvenile court; (2) there were some errors in the jury instructions, but the errors were not prejudicial either individually or cumulatively; (3) the prosecutor’s victim impact statements during closing arguments were improper but not prejudicial; (4) there was sufficient evidence to support the attempted assault and battery charges; (5) Defendant’s aggregate sentence did not deprive the parole board of its statutory authority to consider parole of juveniles after twenty-five years; (6) Defendant’s sentence for murder and aggravated assault of the same victim did not violate double jeopardy; but (7) Defendant’s aggregate sentence violated the Eighth Amendment because it was a de facto life without parole sentence. View "Sam v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for felonious restraint, rendered after a jury trial. The district court sentenced Defendant to incarceration for a period of not less than fifteen months nor more than forty-eight months. On appeal, Defendant argued that the district court abused its discretion when it declined to instruct the jury on the term “bodily injury” and that there was insufficient evidence to establish that the unlawful restraint exposed the victim to a risk of serious bodily injury. The Supreme Court held (1) the district court did not abuse its discretion when it rejected Defendant’s proposed instruction on the definition of “bodily injury”; and (2) there was sufficient evidence to establish the elements of felonious restraint. View "Hurley v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of first-degree felony murder but vacated Appellant’s sentence for the aggravated burglary conviction, the underlying felony. The court held (1) the district court did not err in refusing to instruct the jury that self-defense could be raised as a defense to a charge of felony murder; (2) the district court did not abuse its discretion in denying Appellant’s request to instruct the jury on the definition of the phrase “in the perpetration of” as used in Wyo. Stat. Ann. 6-2-101; but (3) the district court’s issuance of convictions for felony murder and aggravated burglary, the underlying felony, violated protections against double jeopardy. View "Schnitker v. State" on Justia Law

The Supreme Court affirmed the convictions of Appellants, Michael Tibbets and Donna Gifford, each of three counts of child abuse in relation to injuries inflicted upon their children. The district court sentenced Appellants to terms of three to five years for each count, to be served consecutively, but suspended all but Appellants’ first year of confinement in favor of supervised probation. On appeal, Appellants argued that the Sate produced insufficient evidence to support the convictions. The Supreme Court disagreed, holding that the State produced sufficient evidence to prove beyond a reasonable doubt that Appellants recklessly caused mental injury to their children, which was sufficient to sustain their convictions for child abuse under Wyo. Stat. Ann. 6-2-503(b)(ii). View "Gifford v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions of one count of first degree sexual abuse of a minor and one count of second degree sexual abuse of a minor but reversed and remanded for resentencing on Defendant’s first degree sexual abuse conviction. The court held (1) the district court did not err when it denied Defendant’s motion to suppress his statements to law enforcement because Defendant did not make an adequate request for counsel; (2) the district court violated a clear and unequivocal rule of law by allowing the police interview of Defendant to be played to the jury, but Defendant was not prejudiced; (3) the district court did not abuse its discretion when it quashed a subpoena duces tecum without conducting an in camera review of the material; and (4) Defendant was entitled to be resentenced on Count II because it violated Wyo. Stat. 7-13-201. View "Hathaway v. State" on Justia Law

Appellant pled guilty to third-degree sexual abuse of a minor. The district court accepted the guilty plea and imposed five years of supervised probation. Appellant later filed a motion to withdraw his guilty plea, arguing that he had received ineffective assistance of counsel and was prejudiced because he would not have pled guilty were it not for counsel’s deficient performance. The district court denied the motion. The Supreme Court affirmed, holding that counsel’s performance was not deficient, and therefore, the district court did not abuse its discretion in denying Appellant’s motion to withdraw his guilty plea. View "Berger v. State" on Justia Law

The Supreme Court affirmed the ruling of the district court concluding that the probationary portion of a sentence imposed by the municipal court upon Respondent was illegal. Respondent entered a no contest plea to violating Casper Municipal Code 5.08.370(A) and (B). The municipal court sentenced Respondent to, in addition to a fine, six months of unsupervised probation. The district court reversed the municipal court’s sentence, concluding that it was illegal because the Casper ordinances governing the penalty for the possession of alcohol by a minor expressly limited that penalty to a fine and did not provide for a potential penalty of incarceration. The Supreme Court agreed, holding that the district court did not err in concluding that when no confinement is expressly authorized as a punishment for a particular offense, a sentencing court also lacks the authority to impose a period of probation upon a conviction for such an offense. View "City of Casper v. Simonson" on Justia Law

The Supreme Court affirmed Defendant’s aggravated assault and battery conviction and reversed and remanded for acquittal on Defendant’s battery conviction, holding (1) the trial court did not commit plain error or deny Defendant’s Sixth Amendment right to confront witnesses against him when it allowed the emergency medical technician and the physician who treated the victim to testify regarding several statements the victim made to them because the statements were not testimonial; and (2) Defendant’s battery conviction was not supported by sufficient evidence because the jury could not have reasonably concluded that the victim suffered bodily injury when Defendant hit him. View "Villarreal v. State" on Justia Law