Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction on twenty-one counts related to his sexual abuse of his daughter AF, holding that Defendant was not entitled to relief on his allegations of error.At issue was whether the district court abused its discretion in admitting a sexually explicit photograph of AF's mother, Mrs. Freer, and a pornographic father-daughter incest video under Wyo. R. Evid. 404(b). The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting the sexually explicit photograph of Mrs. Freer and the pornographic incest video; (2) Defendant failed to demonstrate that alleged prosecutorial misconduct denied him his right to a fair trial. View "Freer v. Wyoming" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se motion to correct an illegal sentence, holding that the district court did not abuse its discretion in denying the motion.In his motion to correct an illegal sentence, Appellant argued that his two sentences for delivery of a controlled substance should be concurrent because the charges appeared in the same charging document, arose from the same arrest, and were tried under the same district court docket number. The district court denied the motion. The Supreme Court affirmed, holding (1) the two charges for delivery of methamphetamine were separate offenses arising from different transactions; and (2) the trial court did not violate double jeopardy protections by entering consecutive sentences for the two offenses. View "Veatch v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of ten sex crimes against two sisters, A.S. and T.S., holding that Defendant was not entitled to relief on his allegations of error.The State charged Defendant with a total of twenty-two crimes against A.S. and T.S. The jury convicted him of ten of the charges, and the district court sentenced him to seventy-one to eighty-five years in prison. The Supreme Court affirmed, holding (1) Defendant failed to establish that the State violated his right to due process of law under Brady or Giglio; (2) Defendant did not show that his counsel performed deficiently or that his defense was prejudiced by counsel's actions at trial; and (3) the State presented sufficient evidence to support Defendant's convictions for the first-degree sexual assault against T.S. View "Mills v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of aggravated cruelty to animals, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant abandoned his argument that the district court erred when it allowed his wife to invoke spousal privilege in the presence of the jury; (2) the district court did not abuse its discretion when it admitted testimony and evidence from a witness who was not disclosed pretrial; (3) Defendant was not prejudiced by prosecutorial misconduct; and (4) Defendant failed to satisfy the plain error test as to his argument that the district court violated his right against self-incrimination under the Federal and Wyoming Constitutions when it ordered him to participate in the preparation of a presentence investigation as a condition of his bond. View "Berry v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion for sentence reduction and motion to correct an illegal sentence, holding that the district court did not abuse its discretion in denying either motion.Defendant entered an Alford plea to two counts of sexual abuse of a minor child in the third degree and was sentenced to two concurrent terms of three to five years' incarceration. Defendant later filed his second motion for sentence reduction and a motion to correct an illegal sentence. The district court denied both motions. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant's motion for sentence reduction and his motion to correct an illegal sentence. View "Dillard v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of four counts of aggravated assault and battery, holding that the State presented sufficient evidence to support Defendant's aggravated assault and battery convictions.After a jury trial, Defendant was found guilty of four counts of aggravated assault and battery, in violation of Wyo. Stat. Ann. 6-2-502(a)(iii). The district court sentenced Defendant to an aggregate term of forty-two to 108 months' imprisonment. The Supreme Court affirmed, holding that the trial evidence was sufficient for the jury to have found a reasonable doubt all elements of Defendant's conviction. View "Thunder v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion seeking presentence time served credit against his felony drug sentences, holding that Defendant was not entitled to presentence confinement credit against the sentences in the felony drug possession docket.In 2014, Defendant was sentenced on two felony counts of DUI. In 2020, Defendant was arrested and charged with five felonies, including probation violations in his two previous cases. Defendant admitted to the probation violations and pled guilty to two felony drug possession counts. After he was sentenced Defendant filed a pro se motion for time served in presentence incarceration, arguing that he should have received credit for the time served after his arrest and before sentencing. The district court denied the motion. The Supreme Court affirmed, holding that Defendant, who received presentence confinement credit against the sentences in his probation violation cases, was not also entitled to presentnence confinement credit against the sentences in the felony drug possession docket. View "Greene v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellants' joint motion to suppress more than 300 pounds of marijuana law enforcement discovered during a traffic stop on Interstate 80 in Wyoming, holding that the district court did not err when it denied Appellants' motion to suppress evidence.Appellants - Cristian Ramirez and Hector Zapien-Galvan - were pulled over by state troopers for an expired registration. Appellants refused to consent to a search of the car, after which a certified canine alerted to packages containing 320.6 pounds of marijuana. Appellants moved to suppress the evidence, arguing that the officer's conduct in pursuing their vehicle without reasonable suspicion negated the subsequent probable cause for the search. The district court denied the motion. The Supreme Court affirmed, holding that the district court properly denied Appellants' motion to suppress because the underlying traffic stop was both objectively justified and reasonable at its inception and did not violate Wyo. Const. art. I, 4 or the Fourth Amendment. View "Zapien-Galvan v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to withdraw his pleas of no contest to voluntary manslaughter, attempted voluntary manslaughter, two counts of aggravated robbery, and four counts of interference with a peace officer, holding that the district court did not abuse its discretion when it denied Defendant's motion to withdraw his no contest pleas.Defendant pleaded no contest to the charges against him pursuant to a plea agreement with the State. Before he was sentenced, Defendant moved to withdraw his pleas, arguing that his right to a speedy trial was violated and that defense counsel did not provide effective assistance of counsel. The district court denied the motion and sentenced Defendant according to the plea agreement. That Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant's motion to withdraw his pleas. View "McHenry v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction, entered upon his conditional plea of guilty, of felony possession of methamphetamine, holding that the district court did not err in denying Defendant's motion to suppress evidence obtained from his vehicle after law enforcement stopped him for failing properly to signal a left turn.On appeal, Defendant challenged the district court's interpretation of the applicable statute, Wyo. Stat. Ann. 31-5-217, arguing that he complied with the statute and that the officer lacked reasonable suspicion to stop him. The Supreme Court affirmed, holding that Defendant's argument that this Court should interpret the statute to require no more than a turn be made safely ignored the rules of statutory interpretation. View "Anderson v. State" on Justia Law