Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of misdemeanor unlawful possession of a controlled substance. Because it was Defendant’s third or subsequent offense, he was sentenced to three and a half years in prison with 228 days of credit for time served. Defendant appealed, arguing that there was insufficient evidence to convict him because the State failed to meet its burden to show the form of the substance he was charged with possessing. The Supreme Court affirmed Defendant’s conviction and sentence, holding (1) the pertinent statute does not require that the State prove, as an essential element, the form that was possessed by a defendant; and (2) the State met its burden when it proved that Defendant “knowingly or intentionally possessed a controlled substance[.]” View "Daley v. State" on Justia Law

Appellant was convicted of felony first-degree murder and sentenced to life without the possibility of parole. Appellant was nineteen years old at the time the murder was committed. Appellant filed a motion seeking a reduction of his sentence of life without the possibility of parole to life as a matter of law. The district court denied Appellant’s motion for sentence reduction. Appellant appealed, arguing that his life sentence without the possibility of parole violates the Eighth Amendment prohibition against cruel and unusual punishment and the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court affirmed on the grounds that Appellant did not raise the constitutional issues below, the equal protection argument was not cogently presented on appeal, and the Eighth Amendment claim was not of a fundamental nature. View "Poitra v. State" on Justia Law

Defendant entered into a plea agreement pursuant to which Defendant agreed to plead guilty to third degree sexual assault in exchange for a deferred prosecution and a five-year supervised probation. After Defendant had served nearly four years of probation, the district court modified the terms of her probation to require that she submit to and pay for a psycho-sexual evaluation. Defendant appealed, arguing that the district court improperly modified the conditions of her probation where there was no showing of a change in circumstances and no evidence presented to establish the need for the psychosexual evaluation in this case. The Supreme Court affirmed, holding (1) a sentencing court is not specifically required to find a change in circumstances before entering a modification order; and (2) under the circumstances of this case, the district court’s modification was not an abuse of discretion. View "Harada v. State" on Justia Law

After a jury trial, Defendant was found guilty of four counts of first degree sexual abuse involving two minors. Defendant was sentenced to life in prison without the possibility of parole. The Supreme Court affirmed, holding (1) the district court did not err by (i) rejecting Defendant’s ineffective assistance of counsel claim, (ii) determining that the child witnesses were competent to testify, (iii) denying Defendant’s requests for continuances, and (iv) admitting other bad acts evidence under Wyo. R. Evid. 404(b); (2) the district court erred in allowing the admission of some hearsay testimony at trial, but the errors were harmless; and (3) Defendant’s constitutional right to a speedy trial was not violated. View "Griggs v. State" on Justia Law

Pursuant to a plea agreement, Defendant pled guilty to one count of first-degree sexual abuse of a minor. Defendant later filed a motion for sentence modification or reduction under newly discovered evidence arguing that his guilty plea was involuntary and that his trial counsel provided ineffective assistance. The district court construed the motion as both a motion to withdraw Defendant’s guilty plea and to reduce Defendant’s sentence. The district court denied the request to withdraw Defendant’s guilty plea, concluding that Defendant failed to establish newly discovered evidence resulting in manifest injustice, and concluded that it did not have jurisdiction to consider a sentence reduction because Defendant’s motion was untimely. Defendant appealed. The Supreme Court dismissed the appeal, holding that the district court did not have jurisdiction to rule on Defendant’s motion, and therefore, this Court did not have jurisdiction to consider Defendant’s appeal. View "Shue v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder and one count of attempted first degree murder. The jury trial began 210 days after Defendant’s arrest and 869 days after his arraignment. The district court sentenced Defendant to three consecutive sentences of life without the possibility of parole. The Supreme Court affirmed, holding (1) there was no violation of Defendant’s right to a speedy trial under Wyo. R. Crim. P. 48 and the Wyoming and United States Constitutions; (2) Defendant was not denied the effective assistance of counsel by his first appointed counsel; and (3) the district court did not abuse its discretion when it denied Defendant’s challenges for cause against two jurors. View "Castellanos v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of second degree sexual abuse of a minor. Defendant appealed, arguing that the district court erred by refusing his proffered instruction defining the term “inflicts” as used in the charged statute and that the district court erred by refusing to give a definition after the jury requested a dictionary. The Supreme Court affirmed, holding that the district court did not err in refusing Defendant’s proposed instruction or in failing to provide the jury with Defendant’s proffered definition of the term “inflicts” in response to the jury’s request for a dictionary. View "Marfil v. State" on Justia Law

Appellant pled guilty to escape and received a sentence that was suspended in favor of probation. Appellant’s probation was later revoked and the prison sentence for his escape conviction was re-imposed. Appellant subsequently pled guilty of failing to register and sentenced to a term of confinement. Appellant appealed, arguing that the district court erred by failing to consider his request for credit for time spent in presentence confinement. The Supreme Court affirmed, holding that the district court erred in concluding that it lacked the requisite authority to award credit for time served in presentence confinement. Remanded. View "Askin v. State" on Justia Law

Defendant was convicted of two counts of first-degree sexual assault and one count of kidnapping. The Supreme Court affirmed, holding (1) the district court did not commit plain error by failing to instruct the jury on the “incidental rule,” i.e., that confinement would not support a kidnapping conviction unless it was separate from and not merely an incident of the sexual assaults; and (2) there was no plain error in the district court’s reply to a question from the jury that the jurors should review the instructions already given by the court. View "Vaught v. State" on Justia Law

Appellant filed a 42 U.S.C. 1983 civil rights action in the district court asserting four federal constitutional claims and one state law claim, alleging that, while he was an inmate in the state of Wyoming under the supervision and control of the Wyoming Department of Corrections (DOC), he was deprived of his personal property, which violated his right to due process and caused him injury. The district court granted summary judgment on all claims for the DOC. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of the DOC. View "Chapman v. Wyo. Dep’t of Corr." on Justia Law