Justia Constitutional Law Opinion Summaries

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

After a jury trial, Defendant was convicted of sexual assault in the first degree and sexual abuse of a minor in the first degree. Defendant appealed the district court's denial of a continuance motion and the court's admission of uncharged misconduct evidence of his prior conviction for sexual assault of a minor. The Supreme Court affirmed, holding that the district court did not abuse its discretion (1) when it denied Defendant's motion for a continuance of the trial due to a missing witness and in concluding that the unavailable testimony lacked materiality; and (2) in admitting into evidence testimony of the victim that resulted in a prior conviction of Defendant for sexual assault. View "Huckfeldt v. State" on Justia Law

Wife and Husband were divorced by decree. Husband appealed, claiming that the district court (1) abused its discretion in imputing his monthly income and ordering him to pay child support for several months when he was living in the marital home after Wife filed for divorce and ordering him to pay half the cost of the children's past and future activities as an upward deviation of child support; and (2) deprived him of due process in making the above rulings without evidentiary support. The Supreme Court affirmed, holding that Husband waived his right to assert these claims on appeal. View "Verheydt v. Verheydt" on Justia Law

Defendant entered guilty pleas to aggravated burglary, first-degree murder, and conspiracy to commit aggravated burglary. Defendant was sentenced to life imprisonment on the first-degree murder conviction. At the time of the murder, Defendant was a juvenile. The Supreme Court affirmed, holding that Defendant's sentence of life imprisonment for first-degree murder, mandated by Wyo. Stat. 6-2-101(b), was constitutional. After that decision, the U.S. Supreme Court issued Miller v. Alabama, where it held that the Eighth Amendment forbids a sentencing scheme that mandates life in prison without the possibility of parole for juvenile offenders. Based on Miller, Bear Cloud petitioned for certiorari to the U.S. Supreme Court. The U.S. Supreme Court granted the petition, vacated the judgment in Bear Cloud I and remanded the case to the Wyoming Supreme Court. On remand, the Court held that, in light of the Miller decision, Bear Cloud's sentence for his first-degree murder conviction violated the Eighth Amendment and related U.S. Supreme Court case law. Remanded with instructions to resentence Bear Cloud on the first-degree murder conviction. View "Bear Cloud v. State" on Justia Law