Justia Constitutional Law Opinion Summaries

Defendant pleaded guilty to misdemeanor breach of peace and misdemeanor interference with a peace officer. Two days later, the State filed an information charging Defendant with felony interference with a peace officer arising out of the same events as those underlying his misdemeanors convictions. Defendant entered an unconditional plea of no contest to a reduced charge of misdemeanor interference. Defendant appealed, arguing that his second misdemeanor conviction violated his double jeopardy protections. The Supreme Court affirmed, holding (1) Defendant did not waive his double jeopardy claim; and (2) because Defendant committed two separate acts of interference, one inside his home and one outside his home, Defendant could lawfully be prosecuted for each separate offense. View "Redding v. State" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault and battery. Defendant appealed, arguing that the prosecutor committed prosecutorial misconduct by incorrectly instructing the jury regarding the presumption of innocence and by attempting to define “reasonable doubt” to the jury in his closing argument. The Supreme Court affirmed, holding (1) the prosecutor violated a clear and unequivocal rule of law when he made an incorrect statement regarding the presumption of innocence; (2) the prosecutor transgressed a clear and unequivocal rule of law when he defined reasonable doubt for the jury in his closing argument; but (3) while Defendant established that the prosecutor committed two errors that transgressed clear and unequivocal rules of law, the cumulative effect of these errors was not prejudicial. View "Watts v. State" on Justia Law

After a jury trial, Defendant was found guilty of five counts of reckless endangering, three counts of aggravated assault, and one count of eluding police. The Supreme Court affirmed, holding (1) there was sufficient evidence presented at trial to convict Defendant of aggravated assault; (2) the district court erred in admitting evidence of law enforcement officers’ subjective reactions to a fired shot, but the error was not prejudicial; (3) the district court did not abuse its discretion when it denied Defendant’s motion for mistrial based upon prosecutorial misconduct; and (4) the prosecutor’s comments during closing argument did not constitute plain error. View "Hill v. State" on Justia Law

After a jury trial, Defendant was found guilty of four counts of first degree sexual abuse involving two minors. Defendant was sentenced to life in prison without the possibility of parole. The Supreme Court affirmed, holding (1) the district court did not err by (i) rejecting Defendant’s ineffective assistance of counsel claim, (ii) determining that the child witnesses were competent to testify, (iii) denying Defendant’s requests for continuances, and (iv) admitting other bad acts evidence under Wyo. R. Evid. 404(b); (2) the district court erred in allowing the admission of some hearsay testimony at trial, but the errors were harmless; and (3) Defendant’s constitutional right to a speedy trial was not violated. View "Griggs v. State" on Justia Law

Pursuant to a plea agreement, Defendant pled guilty to one count of first-degree sexual abuse of a minor. Defendant later filed a motion for sentence modification or reduction under newly discovered evidence arguing that his guilty plea was involuntary and that his trial counsel provided ineffective assistance. The district court construed the motion as both a motion to withdraw Defendant’s guilty plea and to reduce Defendant’s sentence. The district court denied the request to withdraw Defendant’s guilty plea, concluding that Defendant failed to establish newly discovered evidence resulting in manifest injustice, and concluded that it did not have jurisdiction to consider a sentence reduction because Defendant’s motion was untimely. Defendant appealed. The Supreme Court dismissed the appeal, holding that the district court did not have jurisdiction to rule on Defendant’s motion, and therefore, this Court did not have jurisdiction to consider Defendant’s appeal. View "Shue v. State" on Justia Law

Appellant filed a 42 U.S.C. 1983 civil rights action in the district court asserting four federal constitutional claims and one state law claim, alleging that, while he was an inmate in the state of Wyoming under the supervision and control of the Wyoming Department of Corrections (DOC), he was deprived of his personal property, which violated his right to due process and caused him injury. The district court granted summary judgment on all claims for the DOC. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of the DOC. View "Chapman v. Wyo. Dep’t of Corr." on Justia Law

After a jury trial, Defendant was found guilty of domestic battery and possession of a weapon with intent to threaten. Defendant appealed, arguing (1) the prosecutor improperly asked him a series of questions during his testimony at trial in which the prosecutor repeated statements made by Defendant’s daughter and asked, “was she lying?”; and (2) the district court abused its discretion when it allowed evidence of prior discharge of a gun. The Supreme Court reversed, holding (1) the prosecutor’s questioning was improper, and the error was prejudicial; and (2) the absence of appropriate findings and discussion regarding the admission of the discharge evidence hinders review of the district court’s decision to admit the evidence. Remanded. View "McGinn v. State" on Justia Law

A highway patrol trooper pulled over the driver of a vehicle for following too closely and for having a cracked windshield. Appellant was seated in the front passenger seat. After Appellant appeared to have suffered a seizure, the trooper searched the pocket of Appellant’s jacket, which Appellant had left in the car, and discovered marijuana. Appellant moved to suppress the evidence found by the trooper during his search of the jacket and the vehicle. The district court denied the motion. Thereafter, Appellant entered a conditional guilty plea to one count of possession of a controlled substance. The Supreme Court affirmed the denial of Appellant’s motion to suppress, holding (1) the initial stop of the vehicle in which Appellant was a passenger was justified because the trooper had reasonable suspicion that the driver was breaking the law; and (2) the subsequent search of Appellant’s jacket was supported by the community caretaker exception to the warrant requirement and thus did not violate the Fourth Amendment. View "Allgier v. State" on Justia Law

Defendant pleaded guilty to first-degree murder, aggravated burglary, and conspiracy to commit aggravated burglary. Defendant was sixteen years old when he committed the crimes. After imposing an initial sentence, the district court resentenced Defendant to life in prison with the possibility of parole after serving for twenty-five years on the felony murder charge, to run consecutive to the previously imposed sentence for aggravated burglary of twenty to twenty-five years, and concurrent to the sentence for conspiracy to commit aggravated burglary. The Supreme Court reversed and remanded to the district court with instructions to resentence on all counts, holding that sentencing courts are required to provide an individualized sentencing hearing to weigh the factors for determining a juvenile’s diminished culpability and greater prospects for reform when, as in this case, the aggregate sentences result the functional equivalent of life without parole. Remanded for resentencing. View "Bear Cloud v. State" on Justia Law

Appellant was convicted after a jury trial of aggravated battery stemming from an altercation with his girlfriend and his girlfriend’s sister. The Supreme Court affirmed, holding (1) there was sufficient evidence to establish that the victim suffered serious bodily injury, and therefore, the jury could have determined beyond a reasonable doubt that Appellant was guilty of the crime for which he was convicted; (2) the district court did not commit plain error when it instructed the jury on the theory of self-defense; and (3) the prosecutor’s statements throughout trial were clearly improper, but Appellant was not materially prejudiced as a result of the prosecutor’s misconduct. View "Brown v. State" on Justia Law