Justia Criminal Law Opinion Summaries

After a jury trial, Appellant was convicted of second-degree murder. The Supreme Court affirmed the conviction, holding that the district court did not err or abuse its discretion in (1) excluding evidence relating to the victim’s criminal history; (2) excluding Appellant’s proposed expert testimony regarding the character traits of persons who view depictions of child pornography; (3) declining Appellant’s request to instruct the jury regarding self-defense in a home or habitation; (4) instructing the jury, in relation to Appellant’s claim of self-defense, that it must determine whether Appellant or the victim was the first aggressor in this case; and (5) permitting the State to introduce Wyo. R. Evid. 404(b) evidence despite the State’s late notice of its intent to use the evidence. View "Knospler v. State" on Justia Law

After a jury trial, Appellant was convicted of aggravated assault and battery, simple assault, and strangulation of a household member. The Supreme Court affirmed Appellant’s conviction and sentence for aggravated assault and battery but reversed Appellant’s assault conviction and remanded for an order vacating that conviction and sentence, holding that the district court (1) did not commit plain error in instructing the jury on the elements of aggravated assault and battery under Wyo. Stat. Ann. 6-2-502(a)(i); but (2) erred in instructing the jury to consider assault as a lesser included offense of aggravated assault and battery under Wyo. Stat. Ann. 6-2-502(a)(iii), and the instruction was necessarily prejudicial to Appellant. View "Cecil v. State" on Justia Law

After a jury trial, Defendant was convicted of larceny. The district court revoked Defendant’s probation from a previous case and imposed the remainder of Defendant’s sentence. Defendant appealed in both cases. The Supreme Court affirmed both the probation revocation and the judgment and sentence on the larceny conviction, holding (1) the district court properly revoked Defendant’s probation from the previous case while the larceny case was still pending on appeal; and (2) the district court did not err in the larceny case by providing the jury with an instruction that stated the possession of recently stolen property, when supported by slight corroborative evidence, may support the inference that the possessor participated in the theft; and (3) there was sufficient evidence to convict Defendant of larceny. View "Pena v. State" on Justia Law

After a jury trial, Defendant was found guilty of driving a vehicle while under the influence of intoxicating liquor or controlled substances and was sentenced to six to seven years’ confinement. The Supreme Court affirmed, holding (1) Defendant failed to carry his burden of showing that Wyo. Stat. Ann. 31-5-233(b)(iii)(C) is unconstitutionally vague as applied to Defendant’s conduct; and (2) Defendant failed to carry his burden of showing that his trial attorneys were constitutionally ineffective in failing to present evidence relating to the concentration of alcohol and tetrahydrocannabinol in Defendant’s blood. View "Guilford v. State" on Justia Law

Appellant, an inmate at the Wyoming Medium Correctional Institution, filed a petition for declaratory judgment asking the district court to find that Steve Hargett, the warden of the institution, and Robert Lampert, the director of the Department Prison Division, violated the Wyoming Public Records Act (WPRA) by delaying the production of a record he had requested under the WPRA. Appellant also asked the district court to declare that the Department of Corrections had to produce certain types of records if he requested them in the future. After Appellants filed a motion to dismiss, Appellant filed a motion to amend his petition. The district court dismissed the petition, finding that it did not have jurisdiction under the WPRA to provide the relief Appellant was seeking. The district court did not expressly rule on the motion to amend. The Supreme Court affirmed, holding (1) the district court properly dismissed Appellant’s petition because the relief Appellant sought was not available under the WPRA; and (2) the district court did not abuse its discretion by implicitly denying the motion to amend, as the proposed amendment was futile. View "Guy v. Lampert" on Justia Law

In 1994, Appellant was charged with four counts of first-degree sexual assault and one count of aggravated assault and battery. Appellant entered a plea pursuant to a plea agreement under which the State dismissed all but one of the counts, which it reduced. Appellant pled no contest to the remaining reduced count. In 2013, Appellant was charged with five counts of first-degree rape and three counts of first-degree sexual assault. After a jury trial, Appellant was convicted of four counts of first-degree rape and three counts of first-degree sexual assault. The Supreme Court affirmed, holding (1) the trial court did not violate Appellant’s constitutional right to a speedy trial, as the recent charges concerned crimes committed against victims other than the victim at issue in the 1994 charges; and (2) the prosecution did not violate the 1994 plea agreement by bringing charges against Appellant for those crimes in the present case. View "Nordwall v. State" on Justia Law

After a jury trial, Defendant was found guilty of domestic battery and possession of a weapon with intent to threaten. Defendant appealed, arguing (1) the prosecutor improperly asked him a series of questions during his testimony at trial in which the prosecutor repeated statements made by Defendant’s daughter and asked, “was she lying?”; and (2) the district court abused its discretion when it allowed evidence of prior discharge of a gun. The Supreme Court reversed, holding (1) the prosecutor’s questioning was improper, and the error was prejudicial; and (2) the absence of appropriate findings and discussion regarding the admission of the discharge evidence hinders review of the district court’s decision to admit the evidence. Remanded. View "McGinn v. State" on Justia Law

Appellant was employed as a probation a parole agent when he began a sexual relationship with a probationer he supervised. The State ultimately charged Appellant with second-degree sexual assault under Wyo. Stat. Ann. 6-2-303(a)(vii). Appellant filed a motion to dismiss the charge, asserting that the statute does not apply to probation officers or probationers. The district court denied the motion. Appellant entered a conditional guilty plea to an amended charge of third-degree sexual assault under Wyo. Stat. Ann. 6-2-304, which requires sexual contact under any of the circumstances set forth in section 6-2-303. Appellant appealed the denial of his motion to dismiss. The Supreme Court affirmed, holding that section 6-2-303 applies to persons who are employed as probation officers. View "Yager v. State" on Justia Law

A highway patrol trooper pulled over the driver of a vehicle for following too closely and for having a cracked windshield. Appellant was seated in the front passenger seat. After Appellant appeared to have suffered a seizure, the trooper searched the pocket of Appellant’s jacket, which Appellant had left in the car, and discovered marijuana. Appellant moved to suppress the evidence found by the trooper during his search of the jacket and the vehicle. The district court denied the motion. Thereafter, Appellant entered a conditional guilty plea to one count of possession of a controlled substance. The Supreme Court affirmed the denial of Appellant’s motion to suppress, holding (1) the initial stop of the vehicle in which Appellant was a passenger was justified because the trooper had reasonable suspicion that the driver was breaking the law; and (2) the subsequent search of Appellant’s jacket was supported by the community caretaker exception to the warrant requirement and thus did not violate the Fourth Amendment. View "Allgier v. State" on Justia Law

Appellant was placed on supervised probation. The district court also placed Appellant in an intensive supervision program (ISP). Appellant committed eleven violations of the rules while in the ISP, for which the ISP program gave Appellant an administrative sanction by placing him in a residential community corrections program. Due to Appellant’s violations of the rules while in the ISP, the State filed a petition for probation revocation. The district court revoked Appellant’s probation and imposed the underlying sentence. On appeal, Appellant argued that the ISP violations could not form the basis for a probation revocation because they had previously been subject to administrative sanctions. The Supreme Court reversed, holding that Appellant’s probation was revoked based on violations for which he had previously been punished with administration sanctions, in violation of Wyo. Stat. Ann. 7-13-1107. Remanded. View "Butler v. State" on Justia Law