Justia Constitutional Law Opinion Summaries

Appellant pled guilty to attempted second degree murder in an oral plea agreement and was sentenced to a term of twenty-five to fifty years in prison. The district court also awarded restitution. Appellant later removed to withdraw his plea, claiming that his attorney conspired with the court, misled him about the term he would serve, and coerced him into pleading guilty. The district court denied the motion, concluding that Appellant failed to demonstrate manifest injustice. Appellant appealed, claiming the district court abused its discretion in denying his motion to withdraw his guilty plea and in awarding restitution. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it denied Appellant's motion to withdraw his guilty plea; and (2) the district court had authority to award restitution and to waive public defender fees. View "Chapman v. State" on Justia Law

After a jury trial, Defendant was found guilty of aggravated assault and battery. The jury found Defendant guilty of threatening to use a drawn deadly weapon on another person, which was one of the State's two theories it advanced that Defendant committed aggravated assault. Defendant filed a motion for a new trial because the district court failed to instruct the jury that he had no duty to retreat before "threatening to use a drawn deadly weapon." The district court denied the motion and sentenced Defendant. The Supreme Court affirmed, holding that the jury instructions at issue did not violate a clear and unequivocal rule of law, and therefore, Defendant failed to establish plain error in the district court's denial of Defendant's motion for a new trial. View "Mendoza v. State" on Justia Law

Defendant pleaded guilty to one count of larceny. Defendant appealed, claiming that the factual basis provided by the State for his guilty plea was inadequate as a matter of law because it did not establish the "taking" element of the crime of larceny. The State argued that the factual basis was sufficient because Defendant entered a voluntary plea and the facts established that he committed some crime even though the elements of the larceny statute were not satisfied. The Supreme Court reversed, holding that the district court committed plain error by entering judgment on Defendant's guilty plea when it was not supported by a sufficient factual basis. View "Nguyen v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree felony murder, aggravated burglary, and conspiracy to commit aggravated burglary. Defendant appealed, challenging his convictions on a number of grounds and contending that his sentence of life without the possibility of parole was unconstitutional under the U.S. Supreme Court's recent decision in Miller v. Alabama. The Supreme Court (1) affirmed Defendant's convictions; but (2) vacated Sen's sentences, holding that Sen's sentence of life without the possibility of parole for first-degree felony murder was issued pursuant to a sentencing scheme that violated the Eighth Amendment's prohibition against cruel and unusual punishment. Remanded for resentencing on all counts. View "Sen v. State" on Justia Law

After a jury trial, Defendant was convicted of numerous charges, including false imprisonment, felonious restraint, and aggravated assault and battery. The Supreme Court affirmed, holding (1) the prosecutor did not suppress exculpatory evidence in violation of Defendant's state and federal due process rights; (2) the district court erred in ordering Defendant to disclose witness statements and in limiting Defendant's cross-examination of two prosecution witnesses as a sanction for failure to comply with that order, but the error was harmless; (3) the prosecutor did not commit misconduct by failing to correct the testimony of two witnesses; and (4) the district court did not commit plain error in its sentencing decisions and orders. View "Kovach v. State" on Justia Law

After an adjudicatory hearing in this abuse and neglect case, Appellant was found to have neglected her three children. Appellant appealed, arguing that she was denied fundamental due process rights because the trial court declined to grant a motion to dismiss or to strike witnesses after claimed discovery violations by the State and because the evidence was insufficient to support a finding of neglect. The Supreme Court affirmed, holding (1) the trial judge did not abuse his discretion in dealing with the claimed discovery violations; (2) Appellant received due process; and (3) the evidence was sufficient to support a finding of neglect. View "DL v. State, Dep't of Family Servs." on Justia Law

Defendant was convicted of two counts of first degree sexual abuse of a minor and one count of second degree sexual abuse of a minor upon his three daughters. Defendant appealed. The Supreme Court affirmed, holding (1) the prosecutor did not commit misconduct when he questioned a witness about an exhibit that he did not intend to submit into evidence; (2) as to two of the victims, there was not a fatal variance between the charges in the information and the charges proven at trial, and the evidence was sufficient to support the convictions; and (3) the trial court did not abuse its discretion when it prohibited Defendant's expert witness from testifying about his opinion on what type of sexual abuse allegations were made in this case, as the proposed testimony fell outside the range of permissible opinion testimony. View "Craft v. State" on Justia Law

Pursuant to multiple search warrants the Cheyenne Police Department seized property from Appellant's residence in 1999. Subsequent to that search, Appellant was arrested and convicted on six counts of sexual assault. For the next several years, Appellant litigated issues surrounding the seized property. In 2011, Appellant filed a 42 U.S.C. 1983 complaint for damages arising out of the property confiscated from his home. The district court dismissed Appellant's claim as time barred. The Supreme Court affirmed, holding (1) the district court correctly dismissed the complaint as time barred; and (2) the issues relating to this property are concluded, and in order to ensure that finality, the Court directed that Appellant be prohibited from filing any further litigation relating to the subject matter of this case. View "DeLoge v. Homar" on Justia Law

Greencore Pipeline Company filed an action seeking to condemn easements across property owned by Barlow Ranch for a pipeline to transport carbon dioxide. The parties reached an agreement on the terms of possession and scope of the easements but disputed the amount that would justly compensate Barlow for the partial taking of its property. During trial, Barlow presented evidence of prices paid for other comparable pipeline easements to show the air market value of Greencore's easement. The district court awarded compensation based upon the average of the amounts Greencore had paid other landowners for easements for its carbon dioxide pipeline. Both parties appealed. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) properly ruled that it could consider evidence of comparable easements in determining just compensation; (2) erred in concluding Barlow's proffered easements were not the result of arms' length transactions or sufficiently comparable, while the other Greencore easements were; (3) erred by concluding annual payments were not allowed under Wyoming law; and (4) correctly ruled that the issue of whether Greencore may abandon the pipeline in place was not properly before the Court. View "Barlow Ranch, LP v. Greencore Pipeline Co., LLC" on Justia Law

Defendant conditionally pleaded guilty to possession with intent to deliver marijuana. On appeal, Defendant challenged the district court's denial of his motion to suppress evidence discovered during a search of his vehicle. Defendant argued that because the drug dog sniff was inconclusive, the subsequent search of his vehicle was illegal. The Supreme Court affirmed, holding that the totality of the circumstances was sufficient to find probable clause, as additional facts beyond the dog search were used by the district court to determine that probable cause existed, and an officer of reasonable prudence would have been warranted in the belief that controlled substances would be found in Defendant's vehicle. View "Phippen v. State" on Justia Law