Justia Criminal Law Opinion Summaries

After a trial, Defendant was convicted of six counts of sexual abuse of a minor in the third degree and one count of sexual abuse of a minor in the second degree. During trial, Defendant called a witness who opined about Defendant’s good character when interacting with children. On cross-examination, the trial court allowed the prosecutor to ask the witness if she knew Defendant had two prior convictions for sexually assaulting children. The Supreme Court affirmed, holding that the district court did not abuse its discretion in concluding that Defendant opened the door to character evidence under Wyo. R. Evid. 404(a)(1) and Wyo. R. Evid. 405(a), and the State’s presentation of rebuttal character evidence did not violate Defendant’s constitutional right to present a defense. View "McDowell v. State" on Justia Law

After a jury trial, Defendant was convicted of one count of first degree murder and sentenced to life imprisonment. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in deciding to overrule Defendant’s objection to the court’s admission of certain testimony, as the evidence was not, as Defendant alleged, uncharged misconduct in violation of Wyo. R. Evid. 404(b); (2) the prosecutor did not commit misconduct during closing argument; and (3) the district court did not err in failing to instruct the jury in accordance with the Court’s decision in Eagan v. State. View "Gonzalez-Ochoa v. State" on Justia Law

After a jury trial, Appellant was convicted of felony driving while under the influence of alcohol. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in denying in part a pretrial discovery request made by Appellant; (2) the district court did not violate Appellant’s constitutional right to confrontation when the State’s expert witness testified as to the operation, maintenance, and accuracy of the breath alcohol test machine used in this case; and (3) Appellant’s trial counsel was not ineffective in not calling an expert witness to testify as to the effect of diabetes on the results of a breath alcohol test. View "Anderson v. State" on Justia Law

Defendant entered Alford pleas to promoting prostitution, conspiracy to commit first degree sexual assault, and aggravated assault and battery on a pregnant woman. The victim in this case was Defendant’s girlfriend. The district court imposed suspended sentences of incarceration and ten years probation to run consecutively with a term of imprisonment for the conspiracy charge. One of the conditions of Defendant’s probation was that Defendant have no contact with the victim of the offense or the minor children of the victim and Defendant. Defendant appealed, arguing that the “no contact” condition of his probation was not reasonably related to his rehabilitation and was an encroachment upon his fundamental right to raise his children. The Supreme Court affirmed, holding that the district court did not abuse its discretion in imposing the “no contact” condition of probation in Defendant’s sentencing. View "Perkins v. State" on Justia Law

After a jury trial in 1982, Defendant was found guilty of aggravated robbery and unauthorized use of a vehicle. The Supreme Court affirmed Defendant’s convictions on appeal. Before Defendant began serving his Wyoming sentence, he was released to federal authorities to serve a sentence on unrelated federal charges. In 1988, Defendant was returned to Wyoming to begin serving his Wyoming sentence. In 2013, Defendant filed a petition to correct sentence, arguing, among other things, that his sentence was illegal because he was not given credit for time served in the federal facility and because the sentence was disproportionate to the severity of his crime. The district court denied the motion. The Supreme Court affirmed, holding that Defendant’s claims were barred by the doctrine of res judicata because Defendant had multiple opportunities to assert his current sentencing claims and prosecute appeals related to those claims, and he offered no acceptable justification for his failure to do so. View "Gee v. State" on Justia Law

Defendant entered conditional pleas of guilty to possession of a controlled substance with intent to deliver and conspiracy to deliver a controlled substance. Defendant appealed the district court’s denial of her motion to suppress, arguing that marijuana evidence discovered in her vehicle following a traffic stop was the product of an unlawful detention. Specifically, Defendant argued that her detention was unreasonable because the questioning of Defendant was not tailored to the traffic stop and was not supported by a reasonable suspicion that a crime was being committed. The Supreme Court affirmed, holding that, under the totality of the circumstances, the questioning and detention of Defendant were reasonable and did not violate Wyo. Const. art. I, 4. View "Klomliam v. State" on Justia Law

Appellant was charged and convicted of felony driving while under the influence of alcohol, reckless driving, driving with a suspended license, and driving without an interlock device. On appeal, Appellant argued (1) his constitutional right to a speedy trial was violated because he spent 332 days incarcerated after he was arrested and before his trial began, and (2) the State failed to present sufficient evidence to support the reckless driving conviction. The Supreme Court affirmed, holding (1) although the delay between Appellant’s arrest and trial was approximately eleven months, Appellant’s right to a speedy trial was not violated; and (2) the State presented sufficient evidence to support Appellant’s conviction for reckless driving. View "Mascarenas v. State" on Justia Law

Appellant pleaded guilty to two counts of failure to register as a sex offender. The district court sentenced Appellant to concurrent sentences of two to four and four to six years but suspended the sentences and imposed eight years probation. After Appellant violated the terms of his probation, the district court revoked Appellant’s probation and reimposed the suspended sentence. Appellant subsequently pled guilty to escape and was sentenced to three to seven years suspended in favor of four years probation to be served consecutively to the separate reimposed sentence. Thereafter, Appellant filed a motion to correct an illegal sentence, arguing that the district court was without the authority to “mix a sentence of imprisonment and probation.” The district court denied the motion. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it sentenced Appellant to a period of imprisonment followed by a period of probation. View "Askin v. State" on Justia Law

After a jury trial, Appellant was convicted of several criminal offenses, including attempted second-degree murder. The district court sentenced Appellant to thirty to forty years for the attempted murder conviction with lesser sentences to run concurrently. The district court subsequently denied Appellant's motion for sentence reduction and Appellant's ensuing motion for reconsideration. The Supreme Court affirmed the denial of Appellant's motions, holding (1) the district court did not abuse its discretion in denying Appellant's motion for reduction of sentence; (2) the district court did not violate Appellant's due process rights by denying Appellant's motion to reconsider a sentence reduction; and (2) the State did not commit prosecutorial misconduct by misstating facts in its traverse to Appellant's motion for reduction of sentence. View "Sanchez v. State" on Justia Law

Appellant entered Alford pleas to two felony counts of obtaining public welfare benefits by misrepresentation. Appellant initially pled not guilty to the charges. Appellant appealed, arguing, among other things, that the district court erred when it failed to advise her that a guilty plea to the felonies with which she was charged could result in the loss of her right to possess firearms and her ability to be employed in professions that require carrying and using firearms. The Supreme Court reversed Appellant's conviction and remanded with instructions to reinstate her not guilty plea because the district court did not provide the required statutory firearms advisement when Appellant changed her plea. View "McEwan v. State" on Justia Law