Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of sexual assault in the first degree. Defendant appealed, asserting that the district court abused its discretion by allowing a sexual assault nurse examiner to testify as to statements made by the victim during the physical examination of her. Specifically, Defendant contended that the district court did not properly apply the exception and foundational requirements of Wyo. R. Evid. 803(4), which allows a hearsay exception for statements for purposes of medical diangosis. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it determined that statements made by the victim during her sexual assault examination were admissible under Rule 803(4). View "McLaury v. State" on Justia Law

Appellant entered a conditional plea to felony possession of methamphetamine. Appellant appealed, contending that the district court erred by denying his motion to suppress the results of a vehicle inventory that preceded the planned impoundment of the vehicle but after Appellant had been arrested. Specifically, Appellant argued that the impoundment of his vehicle was unnecessary, that the search was conducted in bad faith, and that police officers should be required to inquire into less intrusive means of safeguarding a vehicle before inventorying one in anticipation of impoundment. The Supreme Court affirmed, holding (1) inventory of a vehicle's contents pending impoundment is constitution when it is authorized by statute or when it is conducted pursuant to the general policy of a law enforcement agency; (2) the state trooper in this case had a statutory basis to impound the vehicle and was required by Highway Patrol policy to inventory the vehicle's contents before impounding it; and (3) the district court did not clearly err in ruling that the trooper acted in good faith. View "Hunnicutt-Carter v. State" on Justia Law

Appellant owned and operated two mobile home parks. In 2000, Appellant changed its practice of including in the rent it charged tenants the cost of water it purchased from the City for the tenants' use. Instead, Appellant installed water meters on each trailer lot and began charging tenants for water usage separately from their rent. In 2008, the Public Service Commission (PSC) determined that Appellant was a public utility and therefore subject to regulation by the PSC. The district court affirmed. The Supreme Court affirmed, holding (1) because Appellant metered a commodity utility to its tenants, it was a public utility under Wyoming law and therefore subject to PSC regulation; and (2) PSC's regulation of Appellant did not violate Appellant's equal protection rights. View "Gosar's Unlimited Inc. v. Wyo. Pub. Serv. Comm'n" on Justia Law

Appellant pled guilty to burglary and attempted assault on a peace officer and nolo contendere to four counts of interference with custody. Appellant received suspended sentences in favor of supervised probation. Thereafter, the State filed a fourth petition to revoke Appellant's probation. After a probation revocation hearing, the district court found Appellant had violated the terms of his probation and, accordingly, revoked Appellant's probation. The Supreme Court affirmed, holding that did not abuse its discretion in (1) revoking Appellant's probation where Appellant failed to prove his conduct in violation of the conditions of his probation was not willful; and (2) ordering involuntary administration of medication to restore Appellant's competency for the probation revocation proceedings. View "DeMillard v. State" on Justia Law

Defendant was charged with burglary and attempted sexual assault. After the attorney Defendant engaged to represent him was severely injured in a motorcycle accident and was unable to continue representing Defendant, the district court allowed Defendant one day to make his choice of a new attorney. After a trial, Defendant was convicted on both counts. Defendant appealed, contending that the district court infringed on his constitutional right to be represented by counsel of his choice by imposing a one-day deadline for choosing new counsel. The Supreme Court affirmed, holding that the district court did not deprive Defendant of a fair opportunity to secure counsel of his own choice. View "Hankins v. State" on Justia Law

The sentence at issue in this case was one of four imposed for unrelated crimes by three district courts between 2007 and 2010. The disputed judgment and sentence was filed in 2011. Later that year, Defendant filed a motion asking the court to correct his sentence, which he claimed was illegal. The Supreme Court remanded the case to the district court to correct the sentence, holding it to be illegal when considered in conjunction with Defendant's other sentences. Following remand for resentencing, the district court issued an amended judgment and sentence. The Supreme Court reversed and remanded for entry of an amended sentence, holding that the sentence imposed on remand was still illegal because the amended sentence required an interruption in service of the period of incarceration, and this sentence must be made to run concurrently with a previously imposed sentence. View "Cothren v. State" on Justia Law

After a jury trial, Defendant was convicted of felony interference with a peace officer. The conviction arose from an incident in which Defendant kicked an officer in the chest, causing him to fall backward onto asphalt pavement. On appeal, Defendant challenged the sufficiency of the evidence, contending that the evidence that the officer was injured by his actions was insufficient to support the conviction. The Supreme Court affirmed the conviction, holding that, in this case, the jury could have reasonably concluded that the State proved beyond a reasonable doubt that the officer was injured when Defendant kicked him. View "Grimes v. State" on Justia Law

Petitioners petitioned to be appointed permanent guardians of their elderly uncle, Thomas Lankford. The district court dismissed the guardianship petition after finding Petitioners were not qualified to serve as guardians because their potential to inherit from Lankford created a disqualifying conflict of interest. Petitioners appealed, asserting (1) the district court erred in finding a conflict of interest, and (2) in the alternative, the guardianship conflict waiver statute, which allows a court of waive conflicts but limits that authority to conflicts of a spouse, adult child, parent, or sibling of a ward, violated their due process and equal protection rights. The Supreme Court affirmed, holding (1) the district court did not err in finding a conflict of interest; and (2) Petitioners' constitutional claims were not properly before the Court. View "Utley v. Lankford" on Justia Law

Appellant was charged while driving under the influence. The Wyoming Department of Transportation suspended Appellant's driver's license. Appellant appealed, arguing that she had not been properly advised as to implied consent. The Office of Administrative Hearings upheld the suspension. Appellant sought review of the administrative suspension in the district court, raising a number of constitutional challenges to a municipal criminal ordinance in addition to the claim that she had not been properly advised under the implied consent statute. The district court concluded (1) the constitutional issues raised by Appellant had not and could have been raised in the administrative hearing, and therefore, the court lacked jurisdiction to consider the claims; and (2) Appellant was properly advised as to implied consent. The Supreme Court affirmed, holding (1) the hearing officer correctly determined that Appellant was properly advised as required by statute; and (2) Appellant's other claims were not and could have been presented in a license suspension proceeding. View "Walters v. State ex rel. Wyo. Dep't of Transp." on Justia Law

After a jury trial, Appellant was convicted of felony stalking. Appellant appealed, contending (1) the amended information did not allege sufficient facts to constitute the offense of felony stalking and did not adequately inform him of the charges against him; and (2) the jury was not adequately instructed with respect to the intent element of the crime. The Supreme Court reversed and remanded for a new trial, holding (1) the district court did not err in permitting the State to amend the information; (2) Appellant was not denied his constitutional right to adequate notice of the charge he was required to defend against; but (3) the district court plainly erred by providing a confusing and misleading jury instruction that combined two of the elements of stalking, and the error in the jury instructions caused prejudice to Appellant. View "Walker v. State" on Justia Law