Justia Constitutional Law Opinion Summaries

Articles Posted in Wyoming Supreme Court
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The Supreme Court affirmed the order of the district court adjudicating JP delinquent and the corresponding order of disposition, holding that Defendant did not receive ineffective assistance of counsel when his attorney failed timely to demand a jury trial.The State filed a delinquency petition alleging that seventeen-year-old JP inflicted sexual intrusion on a thirteen-year-old girl. After a hearing, the juvenile court found that JP committed a delinquent act and sentenced him to one year of juvenile probation. On appeal, JP argued that he was prejudiced by his counsel's failure to timely demand a jury trial. The Supreme Court affirmed, holding that JP failed to show the outcome of his case would have been different if it had been tried to a jury. View "JP v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court sentencing Defendant to the maximum term of fifteen to twenty years for aggravated vehicular homicide and a concurrent six months for driving under the influence, holding that the district court plainly erred when it considered Defendant's silence and community expectations in sentencing her.On appeal, Defendant argued that her constitutional right to a fair sentence was violated when the district court "emphasized, and likely punished, her decision to exercise her constitutional rights at the time of her arrest" and when the court expressed that "the severity of the sentence depended upon the county in which it presided over her." The Supreme Court agreed and remanded the case for a new sentencing hearing, holding that the district court erroneously incorporated constitutionally-prohibited factors into its sentencing decision and that the application of those constitutionally-prohibited factors in sentencing undermined the fairness and integrity of the judicial proceedings. View "Jewkes v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of attempted first-degree arson, entered after a jury trial, holding that the evidence was sufficient to support the conviction and that the district court did not commit plain error by allowing a police officer to testify that gasoline is an accelerant.On appeal, Defendant argued that the State presented insufficient evidence to support his attempted first-degree arson conviction and that a police officer improperly opined as an expert that a liquid he identified as gasoline found in Defendant's home was an accelerant despite not being qualified to testify as an expert under Wyo. R. Evid. 702. The Supreme Court affirmed, holding (1) sufficient evidence supported the conviction; and (2) as to his remaining assignment of error, Defendant failed to satisfy the second prong of plain error review. View "Esquibel v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of felony possession of marijuana, entered following Defendant's conditional guilty plea, holding that the initial traffic stop of Defendant in this case comported with the requirements of the Fourth Amendment to the United States Constitution.In denying Defendant's motion to suppress, the trial court concluded that the initial traffic stop was justified as a drug trafficking investigation. Defendant appealed, arguing that the district court erred in concluding the officer had reasonable suspicion to stop Defendant based on the collective knowledge doctrine. The Supreme Court affirmed, holding that the initial stop was legally justified under the Fourth Amendment, and therefore, the district court did not err in denying Defendant's motion to suppress. View "Guandong v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence, holding that there was no error.Defendant was convicted of three counts of first-degree sexual assault, one count of kidnapping, and one count of aggravated assault and battery. The Supreme Court affirmed on direct appeal. Defendant later filed his motion to correct an illegal sentence, asserting that his sentence violated constitutional prohibitions against double jeopardy. The district court denied relief, determining that Defendant's claims were barred by res judicata and failed on the merits. The Supreme Court affirmed, holding that Defendant's motion to correct an illegal sentence was barred by res judicata. View "Harrell v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence obtained after law enforcement entered her home without a warrant or consent, holding that the district court erred.Defendant entered a conditional plea of guilty to felony driving under the influence. On appeal, Defendant challenged the district court's denial of her motion to suppress, arguing that the record did not support a finding that her husband consented to a law enforcement officer's entry into their home. The Supreme Court reversed and remanded the case, holding (1) the district court erred in concluding that the officer had implied consent to enter the home; and (2) therefore, the officer violated the Fourth Amendment to the United States Constitution. View "Hawken v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of one count of felony possession of a deadly weapon with unlawful intent, holding that there was no error in the proceedings below.Defendant pleaded nolo contendre to one count of felony possession of a deadly weapon with unlawful intent. Defendant subsequently filed a motion to withdraw his no contest plea pursuant to Wyo. R. Crim. P. 32(d), which the district court denied. After Defendant was sentenced he filed a motion to withdraw his plea pursuant to Wyo. R. App. P. 21. The district court denied the motion. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant's Rule 21 motion to withdraw his plea on grounds of ineffective assistance of counsel; and (2) the district court correctly exercised its discretion in denying Defendant's Rule 32(d) motion because Defendant did not present a fair and just reason for withdrawal. View "Delgado v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court convicting Defendant of possession of marijuana, holding that the traffic stop in this case was unreasonable under the totality of the circumstances.Defendant was the passenger in a vehicle that was stopped for following a semi-truck too closely. The officer requested a drug-detection canine to be dispatched to the location and subsequently found approximately forty-two pounds of marijuana. Defendant was subsequently charged with two drug-related counts. Defendant moved to suppress the evidence, arguing that the initial traffic stop was unreasonable. The district court denied the motion to suppress, and Defendant entered a guilty plea to count two. The Supreme Court reversed, holding (1) the traffic violation for following too closely was not objectively justified and was unreasonable at its inception; and (2) therefore, the district court erred by denying Defendant's motion to suppress. View "Levenson v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of possession of marijuana, aggravated fleeing or attempting to elude, reckless endangering, and interference with a peace officer, holding that the district court did not err in denying Defendant's motion to suppress.Defendant pleaded guilty to the offenses, conditioned on his right to appeal the denial of his motion to suppress the fruits of a traffic stop on the ground that the stop violated the Fourth Amendment. On appeal, the parties disputed whether Defendant waived his constitutional claim by filing an untimely motion to suppress. The Supreme Court affirmed, holding (1) Defendant did not waive his Fourth Amendment claim; and (2) the district court did not err in denying Defendant's motion to suppress. View "Barney v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of three counts of delivery of a controlled substance, holding that the exclusion of "distilled spirits, wine, malt beverages, or tobacco" from the Wyoming Controlled Substances Act, Wyo. Stat. Ann. 35-7-1031(a)(ii), did not violate Defendant's constitutional equal protection rights.In his motion to dismiss, Defendant argued that the Act violated his rights to equal protection and substantive due process under the United States and Wyoming Constitutions by operating in an unequal and disparate manner because the Act excludes from its application tobacco and alcohol. The district court denied the motion to dismiss. The Supreme Court affirmed, holding that the regulation of substances contained in the Act was reasonably related to the State's legitimate interests and did not violate Defendant's constitutional right to equal protection. View "Hardison v. State" on Justia Law