Justia Constitutional Law Opinion Summaries

Articles Posted in Wyoming Supreme Court
by
The Supreme Court affirmed Defendant's conviction of attempted sexual abuse of a minor in the second degree, holding that errors in the jury instructions and any deficiencies in defense counsel's performance associated with the instructions were not prejudicial. Specifically, the Court held (1) the evidence presented at trial was sufficient to convict Defendant of attempted sexual abuse of a minor in the second degree; (2) the jury instructions on the elements of attempted sexual abuse of a minor in the second degree were incorrect; (3) it was unnecessary to discuss in detail whether defense counsel's performance in addressing the jury instructions was deficient; and (4) Defendant was not prejudiced by incorrect jury instructions and/or his counsel's deficient performance because the State presented overwhelming showing Defendant was guilty of the crime. View "Weston v. State" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of stalking, in violation of Wyo. Stat. Ann. 62-506(b) and (e)(I), holding that Defendant's First Amendment right to free speech was not violated when he was prosecuted for writing absence letters to the victim. Specifically, the Supreme Court held (1) Defendant's right to free speech under the First Amendment was not violated when the State prosecuted him under section 6-2-506 for sending obscene letters to the victim, and the evidence was sufficient to support the jury's conclusion that the letters were obscene under the ordinary meaning of that term; (2) the district court did not err in instructing the jury or by refusing Defendant's request for a special verdict form; (3) the State presented sufficient evidence to establish that Defendant harassed the victim; and (4) the district court did not abuse its discretion by admitting evidence that Defendant had been warned not to send unsolicited letters. View "Dugan v. State" on Justia Law

by
The Supreme Court affirmed Defendant's aggregate sentence that left him eligible for parole after serving thirty-five years, holding that Defendant failed to show a constitutional violation or an abuse of discretion in the district court's sentencing decision. Defendant was convicted of one count of first-degree murder and twelve counts of aggravated assault and battery for crimes he committed at age sixteen. The district court sentenced Defendant to an aggregate prison term that left him eligible for parole after fifty-two years. The Supreme Court reversed the sentence and remanded for resentencing, holding that the sentence violated the Eighth Amendment because it was a de facto life without parole sentence. On remand, the district court imposed an aggregate sentence that left Defendant eligible for parole after serving thirty-five years. The Supreme Court affirmed, holding that Defendant's sentence did not violate the Eighth Amendment and that the district court did not abuse its discretion in sentencing Defendant. View "Sam v. State" on Justia Law

by
The Supreme Court reversed the judgment of the district court denying Defendant's motions to withdraw his no contest plea to driving under the influence of alcohol, holding that Defendant's no contest plea was not knowing or voluntary, and therefore, the district court abused its discretion in denying Defendant's motions to withdraw his plea. On appeal, Defendant argued that his plea was not knowing or voluntary because the totality of the circumstances showed he did not fully understand the amended charge, the plea agreement, or the consequences of his plea. Further, Defendant claimed that he had insufficient time to speak with his attorney to discuss these matters prior to pleading guilty. The Supreme Court agreed, holding (1) under the specific circumstances of this case, Defendant's plea was not knowing or voluntary; and (2) the district court abused its discretion in not allowing Defendant to withdraw his no contest plea. View "Steffey v. State" on Justia Law

by
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

by
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

by
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

by
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

by
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

by
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