Justia Criminal Law Opinion Summaries

After a four-day jury trial, Defendant was found guilty of multiple counts of first degree sexual assault, battery, and unlawful contact without bodily injury. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress statements he made to a nurse during a sexual assault examination in an alleged violation of Defendant’s rights under Miranda v. Arizona; and (2) Defendant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48(b) and the Sixth Amendment to the United States Constitution. View "Tate v. State" on Justia Law

Defendant was sentenced to two life sentences according to law for crimes he committed in the 1990s. In 2015, Defendant filed a complaint against the Wyoming Board of Parole and the Wyoming Department of Corrections pursuant to the Declaratory Judgment Act, alleging various constitutional violations. The district court dismissed Defendant’s claims. The Supreme Court affirmed, holding (1) Wyo. Stat. Ann. 7-16-2016(a)(i) does not violate Defendant’s equal protection rights because there is a legitimate state interest in treating prisoners differently with respect to the statute; (2) the Wyoming Department of Corrections’ good time policy does not violate Defendant’s equal protection rights because prisoners serving life according to law and prisoners serving a term of years sentence are not similarly situated; (3) the enactment of section 7-16-205(a)(i) did not impliedly repeal Wyo. Stat. Ann. 7-13-402(a); (4) the Wyoming Board of Parole did not violate the doctrine of separation of powers by enacting policies governing the commutation application procedure; (5) Defendant’s due process rights were not violated by the amendment to the commutation application procedure; and (6) the Wyoming Board of Parole’s amendment to the commutation application procedure did not violate Defendant’s constitutional protection against ex post facto laws. View "Bird v. Wyoming Board of Parole" on Justia Law

After a jury trial, Appellant was found guilty of stalking. The district court sentenced Appellant to a term of three to five years in prison. Appellant appealed, arguing that the district court abused its discretion by not granting a mistrial for a violation of an order in limine concerning Wyo. R. Evid. 404(b) evidence and by imposing a discovery sanction that precluded the State from introducing untimely disclosed text messages but allowing the jury to hear testimony about them. The Supreme Court affirmed, holding that the district court did not err in not granting a mistrial and in not imposing a stiffer sanction for the discovery violation. View "Salinas v. State" on Justia Law

After a jury trial, Defendant was convicted of first degree arson for setting a fire in a Walmart store. Defendant was sentenced to a term of ten to eighteen years in prison. Defendant appealed, arguing that there was insufficient evidence to support his conviction because he was intoxicated at the time he set the fire. Therefore, Defendant argued, he should have only been charged with third degree arson. The Supreme Court affirmed Defendant’s conviction and sentence, holding that the State proved that, despite Defendant’s intoxication, Defendant acted maliciously with intent to destroy or damage an occupied structure, and therefore, there was sufficient evidence to support the conviction. View "Harnden v. State" on Justia Law

After Defendant was placed on probation, the State filed a petition to revoke his probation on the grounds that Defendant violated the conditions of his probation. The district court determined that Robinson had violated the terms of his probation because he failed to prove that he maintained employment and repeatedly failed to submit to a polygraph. Defendant appealed, arguing that the district court erred in both the adjudicatory and dispositional phases of the probation revocation process. The Supreme Court affirmed the revocation and imposition of Defendant’s sentences, holding that the district court did not err either in the adjudicatory or the dispositional phases of the probation revocation process. View "Robinson v. State" on Justia Law

After a jury trial, Defendant was convicted of seven counts of felony forgery and one count of misdemeanor theft. Defendant appealed, alleging that her prosecution was motivated by prosecutorial vindictiveness, that she received ineffective assistance of counsel, that the prosecutor argued facts not in evidence during closing arguments, that the district court erred by failing to provide supplemental instructions to the jury, and that the evidence was insufficient to support the convictions. The Supreme Court affirmed, holding (1) there was no plain error in Defendant’s claim of vindictive prosecution, in Defendant’s claim of prosecutorial misconduct, or in the district court’s refusal to provide supplemental instructions to the jury; (2) Defendant’s right to effective assistance of counsel was not violated; and (3) Defendant’s convictions were supported by sufficient evidence. View "Mraz v. State" on Justia Law

Appellant, an inmate at Wyoming’s medium-security correctional facility in Torrington, wrote a letter to the warden asking to inspect certain public records of that institution. The institution’s employees provided him with some, but not all, of the requested documents. Appellant subsequently filed a complaint for order of enforcement and request to show cause, asserting that because the institution’s employees had not timely completed their efforts to fulfill his records requests they effectively refused to comply under the law. The institution subsequently made available to Appellant the remainder of the requested records. Thereafter, the district court dismissed Appellant’s complaint. The Supreme Court affirmed, holding that the district court (1) properly confined the scope of its review to that permitted by the Wyoming Public Records Act, (2) properly found that Appellees fully complied with Appellant’s records request, and (3) properly received information regarding the warden’s initial response to that request. Further, there was no preemption of the WPRA. View "Guy v. Lampert" on Justia Law

Appellant pled no contest to charges of larceny, burglary, and possession of a controlled substance with intent to deliver. Appellant later filed a motion to correct an illegal sentence, arguing that his sentence was illegal because he had not received credit for the time he spent in the county jail after he was sentenced but before he was transferred to a Wyoming Department of Corrections facility. The district court denied the motion. The Supreme Court affirmed, holding that Appellant’s claim was not one properly raised in a motion to correct an illegal sentence under Wyo. R. Crim. P. 35. View "Candelario v. State" on Justia Law

Defendant stole a car in Thermopolis and drove it toward Colorado. Defendant was arrested and jailed in Colorado. The State of Wyoming charged Defendant in Laramie County with receiving stolen property and in Hot Springs County with larceny. The State filed detainers in Colorado pursuant to the Interstate Agreement on Detainers (IAD), and Defendant requested deposition of the charges against him in both counties. Because the State failed to try Defendant within the 180-day period required by the IAD, the Laramie County charges were dismissed with prejudice. The State again failed to timely bring Defendant to trial, and the Hot Springs County charge was dismissed with prejudice. Defendant was then transported back to Colorado. The State then filed another charge against Defendant in Hot Springs County for receiving stolen property. A jury convicted Defendant. The Supreme Court reversed, holding that the dismissal of the Laramie County charge with prejudice barred the State from charging Defendant with the same crime in Hot Springs County. View "Webster v. State" on Justia Law

After a jury trial, Appellant was convicted of one count of burglary. Appellant was sentenced to eighteen to thirty-six months in prison. The Supreme Court affirmed, holding (1) Appellant failed to meet his burden of proving that he was prejudiced by the admission of what he contended was uncharged misconduct evidence; and (2) the State did not commit prosecutorial misconduct rising to the level of plain error in its closing argument, as it could not be said Defendant would have received a more favorable verdict if the comment had not been made. View "Wiese v. State" on Justia Law