Justia Constitutional Law Opinion Summaries

Articles Posted in Wyoming Supreme Court

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The Supreme Court reversed Defendant's conviction of sexual assault in the first degree, holding that cumulative error resulting from prosecutorial misconduct deprived Defendant of a fair trial. On appeal, Defendant argued that the prosecutors committed numerous instances of misconduct during the state's case-in-chief and during the State's closing and rebuttal arguments. The Supreme Court remanded the case for a new trial, holding (1) the prosecutor violated the district court's Wyo. R. Evid. 404(b) order; (2) both prosecutors engaged in improper victim impact argument unrelated to credibility; (3) the prosecutor repeatedly argued facts that were not in evidence; (4) the prosecutor intentionally used inflammatory language in closing argument; and (5) cumulative error deprived Defendant of a fair trial. View "Bogard v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of three counts of child endangerment and one count of possession of a controlled substance, holding that the district court did not violate Defendant's Fifth Amendment right to remain silent by admitting testimony regarding Defendant's contamination of a compelled urine sample. On appeal, Defendant argued that evidence of her contamination of the urine sample was admitted in violation of her right to remain silence because the contamination communicated her guilty knowledge or consciousness of guilt. The State raised the additional question of whether Defendant waived her Fifth Amendment claim when she failed to raise it in the district court. The Supreme Court affirmed, holding (1) Defendant had good cause for failing to raise her Fifth Amendment claim before trial so the claim was not waived; and (2) Defendant's decision to contaminate her sample was neither a communicative act nor an act compelled by the State, and therefore, evidence of Defendant's actions was not protected by the Fifth Amendment, and there was no plain error in the admission of the evidence. View "Herrera v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court granting summary judgment in favor of the University of Wyoming (UW) and dismissing Plaintiff's declaratory judgment action, arguing that the district court abused its discretion in concluding that this declaratory judgment action challenging the legality of a UW regulation barring firearms on the UW campus served a useful purpose. Plaintiff was cited for misdemeanor criminal trespass after he refused to either relinquish his handgun, which he brought to a UW facility. Plaintiff pleaded not guilty in circuit court, obtained a stay of the criminal proceedings, and filed an action for declaratory judgment in district court, arguing that the regulation violated his constitutional right to bear arms. The district court granted summary judgment for UW. The Supreme Court reversed with instructions so that the matter may proceed in the circuit court, holding (1) Defendant had standing the challenge the legality of the regulation because of the pending criminal charge against him; and (2) the district court abused its discretion in concluding that this declaratory judgment action served a useful purpose. View "Williams v. State ex rel., University of Wyoming Board of Trustees" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree sexual abuse of a minor, holding that Defendant was not entitled to relief on any of his allegations of error. Defendant was charged with three counts of first-degree sexual abuse of a minor. Defendant was convicted on counts I and III and acquitted on count II. Defendant appealed his conviction on count I, claiming, among other things, that the trial court committed reversible error because the jury instructions contained identical elements for counts I and II with nothing to differentiate the counts and because the verdict form also failed to distinguish between the two counts. The Supreme Court reversed, holding (1) Defendant waived review of his challenge regarding the description of counts I and II under the invited error doctrine; (2) the evidence was sufficient to convict Defendant on count I; and (3) Defendant's counsel was not ineffective. View "Jackson v. State" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of aggravated kidnapping, sexual abuse of a minor in the first degree, and sexual abuse of a minor in the second degree and sentencing Defendant to a term of eighty to 115 years in prison, holding that Defendant's claims of error were unavailing. Specifically, the court held (1) the district court did not err in denying Defendant's motion for a new trial because Defendant failed to show that his trial counsel was constitutionally ineffective; (2) the district court did not abuse its discretion in admitting other acts evidence under Wyo. R. Evid. 404(b); (3) there was sufficient evidence to sustain Defendant's aggravated kidnapping conviction; and (4) double jeopardy principles did not require the aggravated kidnapping and first-degree sexual abuse of a minor sentences to be merged. View "Winters v. State" on Justia Law

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The Supreme Court affirmed Defendant's convictions of one count each of felony stalking and burglary, holding that Defendant was not entitled to relief on any of his allegations of error. Specifically, the Court held (1) Defendant was not prejudiced when his counsel failed to file a motion to suppress statements Defendant made without receiving a Miranda warning; (2) review of Defendant's claim that the district court erred in failing to suppress Defendant's statements made without a Miranda warning was precluded; (3) the district court did not abuse its discretion in admitting body camera footage of Defendant's traffic stop; and (4) Defendant's convictions were supported by sufficient evidence. View "Bittleston v. State" on Justia Law

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The Supreme Court affirmed the district court's denial of Father's Wyo. R. Civ. P. 60(b)(6) motion for relief from an income withholding order and the district court clerk's assessment of an $85 fee pursuant to Wyo. Stat. Ann. 5-3-206(a)(vii), holding that the district court did not err in denying the motion and that the filing fee was statutorily required. Relying on Rule 60(b)(6), Father filed a pro se motion asking the district court to relieve him from the income withholding order. No responsive pleading was filed, and the district court did not rule on Father's motion for relief. Therefore, Father's motion was "deemed denied" under Rule 6(c)(4). Father appealed, and the district court charged the $85 fee required by section 5-3-206(a)(vii). On appeal, Father argued that the mandatory minimum child support was unconstitutional and that the $85 fee was not properly assessed when no transcripts were requested. The Supreme Court summarily affirmed the denial of Father's Rule 60(b) motion seeking relief from the income withholding order and held that section 5-3-206(a)(vii) required a filing fee of $85 for Father's appeal even though no transcript of testimony was included in the designated record. View "MSC, II v. MCG" on Justia Law

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The Supreme Court affirmed Defendant's conviction of second degree sexual abuse of a minor, third degree sexual abuse of a minor, and contributing alcohol to a minor, holding that the district court did not abuse its discretion in ordering joinder of the sexual abuse charges relating to two victims and did not err in excluding evidence of a prior false sexual abuse allegation by one of the victims. Specifically, the Court held (1) there was no abuse of discretion in the district court's joinder of the offenses for trial where the court reasonably concluded that joinder of the sexual abuse charges was proper under Wyo. R. Crim. P. 8 and 13 and Defendant failed to show that he was prejudiced by the joinder; and (2) the district court did not abuse its discretion or infringe on Defendant's confrontation rights or his right to present a complete defense when it concluded that the victim's prior false statement was not admissible under the rape shield statute. View "Sparks v. State" on Justia Law

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The Supreme Court affirmed the district court's denial of Defendant's motion to suppress, thus affirming Defendant's conviction and sentence, holding that the warrantless detention of Defendant did not violate the Fourth Amendment or Wyo. Const. art. I, 4, 6 and 36. Defendant entered a conditional guilty plea to the charge of possession of marijuana. On appeal, Defendant argued that a police officer unlawfully detained him because he was not violating any laws as he was traveling down the highway and was stopped only pursuant to a temporary roadblock. Defendant asserted that the roadblock was illegal because the officer failed to comply with the statutory requirements set forth in Wyo. Stat. Ann. 7-17-101 through 7-17-103 and that the roadblock otherwise failed to comport with Fourth Amendment standards. The Supreme Court disagreed, holding that the district court properly found that the officer was directing traffic to sure public safety during a rodeo and that Defendant disobeyed the officer's signal to stop. Therefore, the initial stop was legally valid, and the odor of marijuana justified the subsequent search. View "Wright v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of one count of possession with intent to deliver marijuana, holding that the district court did not err in denying Defendant's motion to suppress evidence. On appeal, Defendant argued that the district court erred in denying his motion to suppress evidence obtained after a traffic stop, asserting that the stop's "air of pretext" should cause the Court to reevaluate whether a dog sniff to the exterior of a vehicle require "a righter legal framework" under the Wyoming Constitution than the U.S. Constitution. The Supreme Court affirmed, holding that Defendant failed to present cogent argument under the Wyoming Constitution on appeal. View "Gibson v. State" on Justia Law