Justia Criminal Law Opinion Summaries

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

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