Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence, holding that the district court did not err in ruling that res judicata barred Defendant's motion to correct an illegal sentence.Defendant was convicted of second-degree abuse of a minor and soliciting a minor to engage in sexual relations and sentenced to twenty years as to the sexual abuse conviction and to four to five years on the solicitation conviction, to be served consecutively. Defendant later filed a pro se motion to correct an illegal sentence, arguing that the acts underlying his conviction were one continuous act and that his consecutive sentences violated double jeopardy protections. The district court denied relief ruling that res judicata barred the motion. The Supreme Court affirmed, holding (1) a motion to correct an illegal sentence can be subject to res judicata; and (2) the interests of res judictata in finality and avoiding repetitive litigation were served in this case. View "Peterson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for interference with a peace officer, holding that the district court did not violate Defendant's due process rights by conducting a hearing under Asch v. State, 62 P.3d 945 (Wyo. 2003), in Defendant's absence after he refused to attend the hearing.Defendant, who was serving three consecutive life sentences at the Wyoming State Penitentiary, was charged with interference with a peace officer. Before the scheduled trial date, the State moved to require Defendant to be restrained during trial. The district court conducted an Asch hearing without Defendant and decided to impose restraints at trial. Defendant was convicted of one count of felony interference with a peace officer. The Supreme Court affirmed, holding that Defendant waived any right he had to be present at the Asch hearing by knowingly and voluntarily failing to appear at the hearing due to circumstances within his control. View "Castellanos v. State" on Justia Law

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 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 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 the judgment of the district court convicting Defendant, following a jury trial, of two counts of second-degree sexual abuse of a minor, holding that the prosecutor did not commit prosecutorial misconduct in the underlying proceedings.On appeal, Defendant argued that the prosecutor committed misconduct in the way he referred to and used the testimony of a forensic interviewer in his opening statement and closing argument. The Supreme Court disagreed and affirmed, holding (1) Defendant failed to establish that the prosecutor's statement violated a clear and unequivocal rule of law; and (2) there was no plain error in the State's closing argument. View "State v. Ward" on Justia Law

The Supreme Court affirmed the judgments of the district courts denying Appellants' separate motions to suppress, holding that the Wyoming Constitution does not require that an exterior canine sniff of a vehicle be supported by probable cause.Appellants in these cases were both subjected to an extended investigative detention, and both Appellants were arrested after a canine sniff of their vehicles. On appeal, Appellants argued that the canine sniffs had to be supported by probable cause under Wyo. Const. art. I, 4. The Supreme Court disagreed, holding (1) the Wyoming Constitution does not require probable cause for an exterior canine sniff of a vehicle; and (2) Appellants were not entitled to relief on their remaining allegations of error. View "Tarzia v. State" on Justia Law

The Supreme Court reversed the judgment of the district court ruling that a bylaw adopted by the Uinta County Republican Party governed who could vote in its 2021 officer and state committee-person election, holding that the voting procedure used in the election and the Party's bylaw violated the clear and unambiguous language of Wyo. Stat. Ann. 22-4-105.In making its decision, the district court ruled that the bylaw did not violate the relevant provision of the Wyoming Election Code, Wyo. Stat. Ann. 22-4-105, and that the Party's constitutional right to freedom of association would be unduly burdened if it was prohibited from adopting and utilizing the bylaw. The Supreme Court reversed, holding (1) the district court erred in concluding that the Party acted within its statutory authority by enacting the bylaw and using it for the 2021 election; and (2) the issue of whether section 22-4-15 infringed on the Party's constitutional right to freedom of political association was not properly before the Court. View "Conrad v. Uinta County Republican Party" on Justia Law