Justia Criminal Law Opinion Summaries

Defendant pleaded guilty to first-degree murder, aggravated burglary, and conspiracy to commit aggravated burglary. Defendant was sixteen years old when he committed the crimes. After imposing an initial sentence, the district court resentenced Defendant to life in prison with the possibility of parole after serving for twenty-five years on the felony murder charge, to run consecutive to the previously imposed sentence for aggravated burglary of twenty to twenty-five years, and concurrent to the sentence for conspiracy to commit aggravated burglary. The Supreme Court reversed and remanded to the district court with instructions to resentence on all counts, holding that sentencing courts are required to provide an individualized sentencing hearing to weigh the factors for determining a juvenile’s diminished culpability and greater prospects for reform when, as in this case, the aggregate sentences result the functional equivalent of life without parole. Remanded for resentencing. View "Bear Cloud v. State" on Justia Law

Pursuant to a plea agreement, Defendant pled no contest to one count of interference with a police officer. The State stood by its original plea agreement at the sentencing hearing and recommended a three to five year sentence which would be suspended and Defendant would be placed on probation. The district court did not follow this recommendation and instead sentenced Defendant to incarceration of three to six years. Defendant appealed, arguing that the district court abused its discretion in sentencing. The Supreme Court affirmed, holding that the district court did not abuse its discretion in sentencing Defendant after considering Defendant’s criminal history and the safety of the community. View "Croy v. State" on Justia Law

Plaintiff filed a complaint against four defendants alleging that they conspired to fabricate a mental incompetency determination in connection with criminal proceedings filed against Plaintiff in Utah. The district court dismissed Plaintiff’s case for failing to properly serve the defendants within ninety days of filing the complaint. The Supreme Court reversed, holding (1) questions existed whether the affidavits of service on three of the defendants established a prima case of valid service, and the fourth defendant waived any objection to lack of proper service; (2) the district court did not err in failing to enter a default against the defendants; and (3) the district judge did not err in not granting Plaintiff’s motion to transfer the case to another district court. Remanded for a hearing to determine the validity of service of process. View "Lundahl v. Gregg" on Justia Law

After a jury trial, Defendant was found guilty of larceny, wrongful disposal of stolen property, and burglary arising from the theft and sale of two saddles to a pawn shop. Defendant appealed, arguing that the district court abused its discretion when it admitted other bad acts evidence that Defendant pawned another saddle that allegedly belonged to her sister. The Supreme Court affirmed, holding that because the other bad acts evidence was not admitted for any proper purpose, the district court abused its discretion by allowing it into evidence, but, under the circumstances of this case, the error was harmless. View "Payseno v. State" on Justia Law

Appellant pled guilty to burglary and attempted assault on a peace officer and nolo contendre to four counts of interference with custody. The district court sentenced Appellant to prison on each of the counts but suspended the sentence in favor of supervised probation consisting of two terms: a ten-year term followed by a two-year term. The district court later found that Appellant had violated the terms of his probation, revoked probation, imposed the underlying consecutive sentences, and credited Appellant for time served. The Supreme Court affirmed the probation revocation. Thereafter, Appellant filed a pro se motion to correct illegal sentence, arguing that the first term of his probation was revoked after he had already completed it. The Supreme Court affirmed, holding (1) the doctrine of res judicata applied to bar the issue raised in Appellant’s current appeal; and (2) the district court’s revocation of Appellant’s probation was timely. View "DeMillard v. State" on Justia Law

Appellant was convicted after a jury trial of aggravated battery stemming from an altercation with his girlfriend and his girlfriend’s sister. The Supreme Court affirmed, holding (1) there was sufficient evidence to establish that the victim suffered serious bodily injury, and therefore, the jury could have determined beyond a reasonable doubt that Appellant was guilty of the crime for which he was convicted; (2) the district court did not commit plain error when it instructed the jury on the theory of self-defense; and (3) the prosecutor’s statements throughout trial were clearly improper, but Appellant was not materially prejudiced as a result of the prosecutor’s misconduct. View "Brown v. State" on Justia Law

A defendant was charged with sexual assault of a minor in connection with an AMBER Alert and a missing child. The deputy county attorney requested that the circuit court restrict disclosure of information of the case in accordance with Wyo. Stat. Ann. 6-2-319(a). The circuit court granted the request and sealed the court file and barred news organizations (Appellees) from attending any court proceedings. Appellees moved to intervene to gain access to information pertaining to the case, but the defendant was bound over to the district court before the circuit court ruled on the motion. Appellees filed a declaratory judgment action in the district court seeking a ruling on whether section 6-2-319(a) required the closure of records and proceedings in cases alleging sexual assault. The district court granted summary judgment for Appellees. The Supreme Court affirmed, holding that the circuit court (1) violated the First Amendment when it closed the court proceedings and sealed the court records; and (2) incorrectly interpreted section 6-2-319(a) when it determined that the statute required the court to seal the criminal case file and close all proceedings held in its courtroom without a hearing or findings on the record. View "Circuit Court v. Lee Newspapers" on Justia Law

Defendant, a resident alien who was living in the United States legally, pled guilty to the charge of strangulation of a household member. Before Defendant was sentenced, he learned that his guilty plea would result in his deportation. Defendant subsequently moved to withdraw the plea, arguing that his counsel’s performance was deficient. The district court determined that Defendant had succeeded in demonstrating that his counsel’s performance was deficient, but nonetheless denied Defendant’s request to withdraw his plea, concluding that Defendant failed to prove that he was prejudiced by his counsel’s failure to advise him of the possibility of deportation. The Supreme Court reversed, holding that, because of the exceptional circumstances of Defendant’s counsel’s failure to advise Defendant of his assured deportation, Defendant’s counsel provided ineffective assistance, and, therefore, there was a fair and just reason to allow Defendant to withdraw his guilty plea. View "Ortega-Araiza v. State" on Justia Law

Stowe was driving on a dry highway with her seven-year-old daughter when their vehicle ran off the road. It travelled 318 feet and rolled twice before stopping. A passerby contacted law enforcement and emergency medical services. A trooper was told that Stowe slurred her words and gave off the overpowering odor of an alcoholic beverage. When Stowe first explained the cause of the accident, she told stated that she had swerved to avoid hitting a deer. She later stated that she had swerved to avoid a rabbit. Believing that there was probable cause to arrest Stowe for driving while intoxicated, but needing to locate and examine the crash scene, a trooper asked to have a deputy in Casper go to the hospital and obtain a blood or urine sample. Stowe had been catheterized due to the possibility of back injuries, so a nurse drew urine samples using a port built into the catheter. Tests indicated a .17% alcohol concentration. Stowe entered a conditional nolo contendere plea to a felony charge of fourth-offense driving while under the influence of alcohol. The Wyoming Supreme Court rejected arguments that the results of the test should have been suppressed because her urine was collected pursuant to an unlawful arrest because the officer lacked probable cause to believe that she had been driving while intoxicated and that the result of her urinalysis was invalid because it was collected from a catheter in a manner contrary to methods approved by the State Department of Health.View "Stowe v. State of Wyoming" on Justia Law

Defendant was charged with making a false statement to obtain welfare benefits. Pursuant to a plea agreement, Defendant pled guilty to amended charge of misdemeanor interference with a peace officer and agreed to pay restitution in an amount to be determined after Defendant’s codefendant went through her plea or trial. Nearly two years after Defendant’s plea and sentencing, the district court issued a ruling requiring Defendant to pay restitution in the amount of $2,600. The Supreme Court reversed and vacated the restitution order, holding that the order was not supported by sufficient evidence, as the State presented no evidence that Defendant received or otherwise benefited from a welfare fraud scheme in the amount of $2,600. View "O'Halloran v. State" on Justia Law