Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence that led to Defendant’s conviction for marijuana possession.Corporal Bradley Halter stopped Defendant for a traffic violation. When Defendant attempted to walk away from the traffic stop, Corporal Halter handcuffed Defendant. Because Defendant smelled of marijuana and was impaired, Corporal conducted a search of Defendant’s person, which produced methamphetamine, and, after a subsequent search, marijuana and hashish. After the denial of his motion to suppress, Defendant entered a conditional plea to the possession of marijuana. The Supreme Court affirmed, holding that Corporal Halter’s seizure of the methpahetamine and subsequent search was supported by both the plain feel doctrine and by standard probable cause considerations. View "Maestas v. State" on Justia Law

The Supreme Court affirmed the district court’s order denying Appellant’s motion to suppress the marijuana Trooper Aaron Kirlin discovered in Appellant’s possession during a traffic stop on Interstate 80.Appellant pleaded guilty to possession of marijuana, preserving his right to appeal the district court’s denial of his motion to suppress. On appeal, Appellant argued that Trooper Kirlin unlawfully detained him beyond the original purpose of the traffic stop in violation of his Fourth Amendment rights. The Supreme Court disagreed, holding that the district court did not err in determining that Trooper Kirlin’s extended contact with Appellant was a consensual encounter that did not violate the Fourth Amendment. View "Kennison v. State" on Justia Law

The Supreme Court reversed the order of the district court granting summary judgment in favor of the State in this action filed by Mark Gordon in his capacity as the State Treasurer challenging on its face the constitutionality of legislation that created the State Capitol Building Rehabilitation and Restoration Oversight Group (oversight group). In his complaint, Gordon argued that the legislation violated article 3, section 31 and article 2, section 1 of the Wyoming Constitution because, in part, it did not provide for the state treasurer’s approval of contracts for the capitol restoration project. The district court concluded that Gordon failed to establish that the capitol restoration legislation violated the constitution on its face or that the work being done on the project was the type of repair work contemplated by the framers when they adopted article 3, section 31. The Supreme Court reversed, holding that the capitol restoration legislation was unconstitutional on its face because it impermissibly transferred the state treasurer’s constitutional authority to approve contracts for “repairing and furnishing the halls and rooms used for the meeting of the legislature and its committees” to others. View "Gordon v. State" on Justia Law

The Supreme Court reversed the order of the district court granting summary judgment in favor of the State in this action filed by Mark Gordon in his capacity as the State Treasurer challenging on its face the constitutionality of legislation that created the State Capitol Building Rehabilitation and Restoration Oversight Group (oversight group). In his complaint, Gordon argued that the legislation violated article 3, section 31 and article 2, section 1 of the Wyoming Constitution because, in part, it did not provide for the state treasurer’s approval of contracts for the capitol restoration project. The district court concluded that Gordon failed to establish that the capitol restoration legislation violated the constitution on its face or that the work being done on the project was the type of repair work contemplated by the framers when they adopted article 3, section 31. The Supreme Court reversed, holding that the capitol restoration legislation was unconstitutional on its face because it impermissibly transferred the state treasurer’s constitutional authority to approve contracts for “repairing and furnishing the halls and rooms used for the meeting of the legislature and its committees” to others. View "Gordon v. State" on Justia Law

The Supreme Court remanded this case for a new hearing under Batson v. Kentucky, 476 U.S. 79 (1986), holding that the district court clearly erred by allowing the State to exercise a peremptory challenge to exclude an African American from the jury. The record supported the validity of only one of the prosecutor’s race-neutral reasons for his peremptory challenge and did not show that the district court would credit this reason alone. Specifically, one of the prosecutor’s two explanations for the peremptory challenge upon which the district court relied failed, and the record did not show that the district court would find that the prosecutor was motivated solely by the valid grounds. Therefore, the case must be remanded for a new Batson hearing in which the district court must reassess the prosecutor’s credibility in light of the discrepancy between the record and his explanation. View "Roberts v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant’s motion to suppress evidence obtained as a result of a detention and subsequent search of his vehicle.Defendant was charged with one count of possession of a controlled substance and one count of a controlled substance with intent to deliver. Defendant moved to suppress evidence based on the roadside search of his car, arguing that the initial traffic stop was not justified by reasonable suspicion and that the subsequent detention was unconstitutional. The district court denied the motion to suppress. On appeal, Defendant conceded that the initial stop was justified but challenged the investigative detention. The Supreme Court affirmed, holding that the trial court did not err in denying Defendant’s motion to suppress. View "Harris v. State" on Justia Law

The Supreme Court affirmed the decision of the district court finding that Plaintiffs, two Wyoming citizens, lacked standing to challenge legislation that authorized two construction projects while maintaining a degree of legislative control and that Plaintiffs’ proposed amendment to their complaint would be futile.In their complaint, Plaintiffs alleged that the legislation at issue violated the Wyoming Constitution and that government officials unconstitutionally engaged in a pattern of letting state contracts without competitive bidding or required safeguards. The district court found that Plaintiffs lacked standing and that their proposed amendment to add a third plaintiff who would have alleged economic harm resulting from the contracting practices would be futile. The Supreme Court affirmed, holding (1) Plaintiff lacked standing to bring this lawsuit; and (2) because there was no justiciable controversy, this court declines to address the constitutionality of a statute enacted in 2017 that prohibits naming a legislator in a lawsuit if he or she is sued in an official capacity. View "Allred v. Bebout" on Justia Law

The Supreme Court affirmed Defendant’s conviction for one count of conspiracy to deliver a controlled substance, methamphetamine, thus rejecting Defendant’s claims of error on appeal. Specifically, the court held (1) the trial court did not abuse its discretion or commit plain error in admitting certain testimony into evidence; (2) the trial court did not err in denying Defendant’s motion to dismiss on Fifth Amendment double jeopardy grounds; and (3) plain error did not occur when a law enforcement witness offered his opinion that Defendant committed the crime of conspiracy to deliver methamphetamine. View "Garriott v. State" on Justia Law

Steven McLaren challenged his convictions for five felonies stemming from a bizarre and violent encounter with his girlfriend in 2014. McLaren owned 57 cats. He and his girlfriend, Jennifer Evans, referred to the cats as their “kids” or “the kid.” In March 2014, one of Mr. McLaren’s exotic Savannah kittens, Cameo, was sick, so he and Evans took it to a veterinary clinic for treatment. McLaren testified that he had injected “somewhere between a quarter and a third of a gram” of methamphetamine right before he noticed Cameo was ill, had not slept for days, and had been experiencing hallucinations since the night before. He was under the impression that Evans was attempting to harm or kill the kitten. After taking the kitten to the vet, McLaren and Evans drove around for a time. Though nothing seemed out of the ordinary at that time, McLaren came to a complete stop in the southbound lane in front of an oncoming Pepsi truck. Evans attempted to get out of the truck, but he pulled her by her hair back into the truck and locked the doors, telling her that her “kids deserved a better mother” and that she “was going to die today.” The Pepsi truck swerved around them, and McLaren turned off Highway 191, onto Wild Horse Loop. As he drove down Wild Horse Loop, Evans fought with McLaren and continued to attempt to get out, kicking the truck into park several times. McLaren also continued to hit and punch Evans; he grabbed her throat and forced her to the floorboard of the truck. At some point, McLaren opened the passenger door and Evans fell. She testified that McLaren stood over her, pulled her head to the left and the right, “trying to rip my head off,” and then let go. As soon as McLaren released her, Evans got up and ran toward Highway 191, where a truck stopped to assist her. When Evans arrived at the emergency room, she had two lacerations on her head and numerous bruises. Appealing his felonies, McLaren argued the trial court violated his due process rights when it failed to order a third competency evaluation and when it allowed defense counsel to assert a plea of not guilty by reason of mental illness (NGMI) against his will. He also argued the jury instructions contained structural error because they did not require the State to prove he did not act in a sudden heat of passion to establish attempted second-degree murder and that the trial court abused its discretion when it denied defense counsel’s motion for mistrial after McLaren’s outburst during trial. The Wyoming Supreme Court concluded that, while the trial court did not improperly fail to order a competency hearing, it violated McLaren’s due process rights when, in spite of McLaren’s numerous declarations that he did not wish to proceed with the NGMI plea, it allowed defense counsel to assert the plea at trial. View "McLaren v. Wyoming" on Justia Law

A jury convicted appellant Donald Dean Foltz, Jr. of first-degree murder and the district court sentenced him to life without the possibility of parole. Foltz was accused of child abuse towards his girlfriend’s two-year-old son. Foltz appealed his conviction, arguing the district court erred when it denied his motion for judgment of acquittal because he contended the evidence was insufficient to support the charged against him. After review of the trial court record, the Wyoming Supreme Court found no reversible error and affirmed Foltz’s conviction. View "Foltz, Jr. v. Wyoming" on Justia Law