Justia Constitutional Law Opinion Summaries

Defendant pled guilty to two counts of first degree murder and one count of larceny. Defendant was eighteen years old when he committed the crimes. At that time, the age of majority in Wyoming was nineteen. Defendant was sentenced to two consecutive sentences of life imprisonment on the murder counts. Defendant later filed a pro se motion to correct an illegal sentence under Wyo. R. Crim. P. 35, arguing that his life sentences violated the constitutional prohibition of cruel and unusual punishment. The Supreme Court affirmed, holding that Defendant’s sentence did not violate state law because the Eighth Amendment sentencing protections announced in Miller v. Alabama extend only to offenders under the age of eighteen. View "Nicodemus v. State" on Justia Law

Appellant was convicted of first-degree felony murder, aggravated burglary, and conspiracy to commit aggravated burglary. After the United States Supreme Court’s decision in Miller v. Alabama and the Supreme Court’s decision in Bear Cloud v. State, the Supreme Court vacated Appellant’s sentences for resentencing on all counts. Upon resentencing, the court sentenced Appellant to an aggregate sentence will require him to serve at least thirty-five years before he becomes parole eligible. Appellant appealed, arguing that his aggregate sentence violates constitutional protections against cruel and unusual punishment. The Supreme Court affirmed, holding (1) Appellant’s aggregate sentence is not a de facto sentence of life without the possibility of parole and does not violate the Eighth Amendment; and (2) Appellant’s aggravated burglary sentence of ten to twenty-five years is not grossly disproportionate or unconstitutional. View "Sen v. State" on Justia Law

Defendant entered a conditional guilty plea to felony possession of methamphetamine. Defendant reserved the right to challenge the denial of his motion to suppress the warrantless pat-down search of his person. On appeal, Defendant argued that the pat-down search amounted to an illegal warrantless search because there were no exigent circumstances to necessitate such a search. The Supreme Court affirmed the denial of Defendant’s motion to suppress, holding that the district court did not err in concluding that, based upon the totality of the circumstances, law enforcement was justified in conducting a warrantless pat-down search for officer safety reasons. View "Sweets v. State" on Justia Law

After Crook County Weed and Pest Control District applied herbicides to control leafy spurge found on property owned by Bush Land Development Company and Victoria Bush (collectively, Bush), many trees in the area of the spraying died. Bush filed this inverse condemnation action in the district court alleging that it was entitled to just compensation for the loss of its trees as a result of the District’s improper application of herbicides. The district court dismissed Bush’s claim, concluding that the action was not proper under the inverse condemnation statute. The Supreme Court affirmed on other grounds, concluding that the inverse condemnation was not properly before the district court because Bush failed to exhaust its administrative remedies before claiming inverse condemnation. View "Bush Land Development Co. v. Crook County Weed & Pest Control District" on Justia Law

Defendant entered a conditional no contest plea to possession of methamphetamine with the intent to distribute. Defendant appealed, arguing that the district court erred in denying his motion to suppress and finding that Defendant consented to continued detention when law enforcement told him “he was free to leave” but continued to have [its] red and blue emergency overhead lights activated. The Supreme Court affirmed, holding that, under the totality of the circumstances in this case, a reasonable person in Defendant’s position would have felt free to decline the law enforcement officer’s request, and therefore, the contact between the officer and Defendant was consensual. View "Tibbetts v. State" on Justia Law

Appellant Bruce Williams asked the Circuit Court for a copy of part of a presentence investigation report in a criminal case. The circuit court denied his request. He brought a petition for a writ of mandamus asking the district court to require that the circuit court release the records. The district court dismissed the case. He appealed, claiming a constitutional right as a member of the public to access these records. Because he did not present his constitutional arguments to the district court, the Supreme Court affirmed. View "Williams v. Tharp" on Justia Law

After a jury trial, Appellant was convicted of conspiracy to deliver a controlled substance. The district court sentenced Appellant to not less than four years nor more than eight years in prison. Appellant appealed, claiming that he received ineffective assistance of counsel because “a skilled criminal defense advocate would likely be able to secure a more favorable agreement than was obtained in his current sentence.” The Supreme Court affirmed, holding that Appellant failed to establish that he was prejudiced by counsel’s alleged deficient performance, and therefore, it was unnecessary to address the deficiency prong of the ineffectiveness standard. View "McNaughton v. State" on Justia Law

After a jury trial, Defendant was convicted of attempted second-degree murder and aggravated assault and battery. The district court sentenced Defendant to forty to fifty years in prison for the attempted murder and to a term of fifteen to fifty years for the aggravated assault and battery. Defendant appealed, challenging his sentences. The Supreme Court affirmed, holding (1) the cumulative sentences Defendant received upon conviction of the offenses of attempted second-degree murder and aggravated assault and battery did not offend principles of double jeopardy; and (2) the statutes under which Defendant was convicted were not unconstitutionally vague, either on their face or as applied to the facts of Defendant’s case. View "Jones v. State" on Justia Law

After a four-day jury trial, Defendant was found guilty of multiple counts of first degree sexual assault, battery, and unlawful contact without bodily injury. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress statements he made to a nurse during a sexual assault examination in an alleged violation of Defendant’s rights under Miranda v. Arizona; and (2) Defendant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48(b) and the Sixth Amendment to the United States Constitution. View "Tate v. State" on Justia Law

Defendant was sentenced to two life sentences according to law for crimes he committed in the 1990s. In 2015, Defendant filed a complaint against the Wyoming Board of Parole and the Wyoming Department of Corrections pursuant to the Declaratory Judgment Act, alleging various constitutional violations. The district court dismissed Defendant’s claims. The Supreme Court affirmed, holding (1) Wyo. Stat. Ann. 7-16-2016(a)(i) does not violate Defendant’s equal protection rights because there is a legitimate state interest in treating prisoners differently with respect to the statute; (2) the Wyoming Department of Corrections’ good time policy does not violate Defendant’s equal protection rights because prisoners serving life according to law and prisoners serving a term of years sentence are not similarly situated; (3) the enactment of section 7-16-205(a)(i) did not impliedly repeal Wyo. Stat. Ann. 7-13-402(a); (4) the Wyoming Board of Parole did not violate the doctrine of separation of powers by enacting policies governing the commutation application procedure; (5) Defendant’s due process rights were not violated by the amendment to the commutation application procedure; and (6) the Wyoming Board of Parole’s amendment to the commutation application procedure did not violate Defendant’s constitutional protection against ex post facto laws. View "Bird v. Wyoming Board of Parole" on Justia Law