Justia Criminal Law Opinion Summaries

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

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