Justia Criminal Law Opinion Summaries

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

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