Justia Constitutional Law Opinion Summaries

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

A defendant was charged with sexual assault of a minor in connection with an AMBER Alert and a missing child. The deputy county attorney requested that the circuit court restrict disclosure of information of the case in accordance with Wyo. Stat. Ann. 6-2-319(a). The circuit court granted the request and sealed the court file and barred news organizations (Appellees) from attending any court proceedings. Appellees moved to intervene to gain access to information pertaining to the case, but the defendant was bound over to the district court before the circuit court ruled on the motion. Appellees filed a declaratory judgment action in the district court seeking a ruling on whether section 6-2-319(a) required the closure of records and proceedings in cases alleging sexual assault. The district court granted summary judgment for Appellees. The Supreme Court affirmed, holding that the circuit court (1) violated the First Amendment when it closed the court proceedings and sealed the court records; and (2) incorrectly interpreted section 6-2-319(a) when it determined that the statute required the court to seal the criminal case file and close all proceedings held in its courtroom without a hearing or findings on the record. View "Circuit Court v. Lee Newspapers" on Justia Law

Defendant, a resident alien who was living in the United States legally, pled guilty to the charge of strangulation of a household member. Before Defendant was sentenced, he learned that his guilty plea would result in his deportation. Defendant subsequently moved to withdraw the plea, arguing that his counsel’s performance was deficient. The district court determined that Defendant had succeeded in demonstrating that his counsel’s performance was deficient, but nonetheless denied Defendant’s request to withdraw his plea, concluding that Defendant failed to prove that he was prejudiced by his counsel’s failure to advise him of the possibility of deportation. The Supreme Court reversed, holding that, because of the exceptional circumstances of Defendant’s counsel’s failure to advise Defendant of his assured deportation, Defendant’s counsel provided ineffective assistance, and, therefore, there was a fair and just reason to allow Defendant to withdraw his guilty plea. View "Ortega-Araiza v. State" on Justia Law

Stowe was driving on a dry highway with her seven-year-old daughter when their vehicle ran off the road. It travelled 318 feet and rolled twice before stopping. A passerby contacted law enforcement and emergency medical services. A trooper was told that Stowe slurred her words and gave off the overpowering odor of an alcoholic beverage. When Stowe first explained the cause of the accident, she told stated that she had swerved to avoid hitting a deer. She later stated that she had swerved to avoid a rabbit. Believing that there was probable cause to arrest Stowe for driving while intoxicated, but needing to locate and examine the crash scene, a trooper asked to have a deputy in Casper go to the hospital and obtain a blood or urine sample. Stowe had been catheterized due to the possibility of back injuries, so a nurse drew urine samples using a port built into the catheter. Tests indicated a .17% alcohol concentration. Stowe entered a conditional nolo contendere plea to a felony charge of fourth-offense driving while under the influence of alcohol. The Wyoming Supreme Court rejected arguments that the results of the test should have been suppressed because her urine was collected pursuant to an unlawful arrest because the officer lacked probable cause to believe that she had been driving while intoxicated and that the result of her urinalysis was invalid because it was collected from a catheter in a manner contrary to methods approved by the State Department of Health.View "Stowe v. State of Wyoming" on Justia Law

Pursuant to the Wyoming Public Records Act, Plaintiff requested from the Office of the Governor and the Wyoming Game & Fish Department (together, the State) documents related to the status of grizzly bears under the Endangered Species Act. The State provided some documents and withheld others on grounds of the deliberative process privilege and the attorney-client communication privilege. The district court held (1) the Act incorporates the deliberative process privilege as a ground to exempt documents from disclosure under the Act, and the documents withheld under the deliberative process privilege were properly withheld by the State; and (2) two of the three documents withheld under the attorney-client privilege were properly withheld. The Supreme Court (1) affirmed the district court’s ruling with respect to the documents withheld under the attorney-client privilege; (2) affirmed the district court’s ruling that the Act incorporates the deliberate process privilege; but (3) concluded that some of the documents withheld pursuant to the deliberative process privilege were not properly withheld because they were outside the scope of the privilege’s protection. View "Aland v. Mead" on Justia Law

Defendant pled guilty to one count of solicitation to commit property destruction. On appeal, Defendant argued (1) the district court lacked subject matter jurisdiction because he was in West Virginia at the time of the alleged solicitation, and (2) he received ineffective assistance of counsel. The Supreme Court affirmed, holding (1) the State had subject matter jurisdiction to prosecute Appellant for charges specified in the charging Information, as Defendant intended his criminal actions to have an effect in Wyoming; and (2) Appellant failed to carry his burden of showing that his representation by trial counsel was so ineffective that it rendered Appellant’s guilty plea involuntary. View "Turner v. State" on Justia Law

Defendant entered a conditional Alford plea to possession of a controlled substance. On appeal, Defendant challenged the district court’s denial of her motion to suppress evidence, arguing that she should have been permitted to leave the scene of a traffic stop when she asked to leave, that the arresting officer lacked reasonable suspicion to detain her, and that she should have been read her Miranda rights. The Supreme Court affirmed, holding (1) law enforcement had reasonable, articulable suspicion on which to detain Defendant; and (2) under the circumstances of this case, Defendant was not entitled to receive Miranda rights. View "Engdahl v. State" on Justia Law

Defendant pleaded guilty to driving while under the influence of alcohol (DWUI). This was Defendant’s fourth such offense within the previous ten years, making it a felony under Wyo. Stat. Ann. 31-5-233(e) and subject to a sentence enhancement. Defendant filed a motion to strike two of four prior convictions, claiming that the two prior DWUI convictions were not constitutionally obtained and therefore should not have been relied upon for sentence enhancement purposes. The district court denied Defendant’s motion, ruling that because Defendant had not appealed from his earlier convictions the convictions could not be overturned. The court then enhanced Defendant’s conviction to a felony and sentenced Defendant accordingly. The Supreme Court affirmed Defendant’s enhanced sentence, holding that Defendant’s underlying convictions were constitutionally obtained. View "Derrera v. State" on Justia Law