Justia Criminal Law Opinion Summaries

After a jury trial, Appellant was convicted for possession, delivery, and conspiracy to deliver methamphetamine. On appeal, Defendant challenged the admission of photographic evidence of items in his home containing methamphetamine, arguing that the evidence constituted evidence of uncharged misconduct under Wyo. R. Evid. 404(b) because it suggested that Appellant was manufacturing methamphetamine. The State responded that the evidence was substantive evidence of the crimes charged and was thus not uncharged misconduct evidence. The Supreme Court affirmed the convictions, holding that the district court did not abuse its discretion in admitting the challenged evidence because it was intrinsic to the crimes charged and was not uncharged misconduct evidence. View "Hernandez v. State" on Justia Law

After an investigation, police learned that Defendant, a band teacher, had sexual relations with three students at Rock Springs High School. The State charged Defendant with a total of fifteen counts of sexual abuse of a minor. Pursuant to a plea deal, Defendant pleaded guilty to three counts, and the State dismissed the remaining charges. At the sentencing hearing, several students, including two of the victims, testified on Defendant’s behalf. The district court sentenced Defendant to a fifteen to twenty-five-year sentence for one count of sexual abuse of a minor in the first degree, to be served concurrently with the sentences imposed on the other counts. The Supreme Court affirmed, holding that the district court (1) properly exercised its discretion in sentencing Defendant and in considering statements made by the victims as aggravating rather than mitigating; and (2) did not violate Defendant’s due process rights when it recessed his sentencing hearing and continued it to the next day. View "Thompson v. State" on Justia Law

Appellant was convicted of felony child abuse for physically abusing his fifteen-year-old daughter during a heated conversation about the daughter’s poor grades. The statute under which Appellant was convicted expressly provides that a defendant is not guilty of child abuse if the physical injury results from “reasonable corporal punishment.” Appellant argued that the jury instructions in this case were faulty because the district court failed properly to instruct the jury as to the elements of felony child abuse because the jury was not instructed that the State must prove beyond a reasonable doubt that the physical injury was not the result of discipline Appellant was permitted to administer. The Supreme Court reversed and remanded for a new trial, holding that district court failed properly to instruct the jury on the elements of felony child abuse, and the court’s error created confusion as to the burden of necessary elements of the crime and the burden of proof, resulting in prejudice to Appellant. View "Andersen v. State" on Justia Law

Defendant pleaded guilty to first-degree felony murder and aggravated burglary. Defendant was sentenced to life imprisonment on the murder charge. Defendant did not appeal his conviction. Instead, Defendant filed several motions and petitions concerning his conviction and sentence, to no avail. Here Defendant filed a number of motions challenging his sentence, claiming that it was illegal because in 2013 he was transferred from Wyoming to Virginia to serve out his sentence. The district court denied Defendant’s motions. The Supreme Court affirmed, holding that because Defendant challenged the way in which the State executed his sentences, rather than the legality of his sentences, his transfer to Virginia did not constitute an illegal sentence. View "Garnett v. State" on Justia Law

Defendant pled guilty to one count of solicitation to commit property destruction. On appeal, Defendant argued (1) the district court lacked subject matter jurisdiction because he was in West Virginia at the time of the alleged solicitation, and (2) he received ineffective assistance of counsel. The Supreme Court affirmed, holding (1) the State had subject matter jurisdiction to prosecute Appellant for charges specified in the charging Information, as Defendant intended his criminal actions to have an effect in Wyoming; and (2) Appellant failed to carry his burden of showing that his representation by trial counsel was so ineffective that it rendered Appellant’s guilty plea involuntary. View "Turner v. State" on Justia Law

Defendant entered a conditional Alford plea to possession of a controlled substance. On appeal, Defendant challenged the district court’s denial of her motion to suppress evidence, arguing that she should have been permitted to leave the scene of a traffic stop when she asked to leave, that the arresting officer lacked reasonable suspicion to detain her, and that she should have been read her Miranda rights. The Supreme Court affirmed, holding (1) law enforcement had reasonable, articulable suspicion on which to detain Defendant; and (2) under the circumstances of this case, Defendant was not entitled to receive Miranda rights. View "Engdahl v. State" on Justia Law

Defendant pleaded guilty to driving while under the influence of alcohol (DWUI). This was Defendant’s fourth such offense within the previous ten years, making it a felony under Wyo. Stat. Ann. 31-5-233(e) and subject to a sentence enhancement. Defendant filed a motion to strike two of four prior convictions, claiming that the two prior DWUI convictions were not constitutionally obtained and therefore should not have been relied upon for sentence enhancement purposes. The district court denied Defendant’s motion, ruling that because Defendant had not appealed from his earlier convictions the convictions could not be overturned. The court then enhanced Defendant’s conviction to a felony and sentenced Defendant accordingly. The Supreme Court affirmed Defendant’s enhanced sentence, holding that Defendant’s underlying convictions were constitutionally obtained. View "Derrera v. State" on Justia Law

After a jury trial in Sweetwater County, Appellant was found guilty of third-degree sexual abuse of a minor for offenses committed against a fifteen-year-old girl on a Greyhound bus. Defendant filed a motion for judgment of acquittal, arguing that the State had not offered evidence to prove that the crime had occurred in Sweetwater County. The Supreme Court affirmed, holding (1) that prosecutor’s tactics did not amount to judge-shopping so as to deprive Appellant of his constitutional right to due process; (2) the jury was correctly instructed regarding venue; (3) the evidence established that venue in Sweetwater County was proper; and (4) the prosecutor’s misstatement of the law regarding venue in her closing argument did not constitute reversible error. View "Anderson v. State Employment Sec. Div." on Justia Law

After a jury trial, Defendant was found guilty of larceny by bailee. Defendant appealed, arguing (1) the district court erred in excluding alternate suspect evidence and in giving an improper jury instruction, and (2) the evidence was insufficient to support the conviction. The Supreme Court reversed the conviction and remanded with instructions to enter a judgment of acquittal, holding that the evidence presented at trial was not sufficient under Wyoming law to support the guilty verdict, given Defendant’s the lack of any evidence of motive, ill will, any attempt to avoid apprehension by law enforcement, or physical evidence linking Defendant with the stolen property. View "Mraz v. State" on Justia Law

After a jury trial, Appellant was convicted on two separate charges of delivery of a controlled substance and one charge of possession of a controlled substance. After the Supreme Court affirmed on appeal, Appellant filed a motion to correct an illegal sentence, asserting that his two convictions and sentences on two charges of delivery resulted in his being punished twice for the same offense in violation of the prohibition against double jeopardy. The district court denied the motion. The Supreme Court affirmed, holding that because Defendant committed two separate and distinct crimes on two separate dates, each charge included an element that was unique, and thus, double jeopardy did not attach. View "Mebane v. State" on Justia Law