Justia Constitutional Law Opinion Summaries

Appellant Jimmy Dean Smallfoot entered a conditional guilty plea to a charge of possession with intent to deliver a controlled substance. Smallfoot reserved the right to appeal the district court's denial of his motion to suppress the marijuana discovered inside his residence. On appeal, Smallfoot claimed the drug evidence should have been suppressed because it was the fruit of a constitutionally infirm warrantless entry into his home. The Supreme Court affirmed the district court's suppression ruling, holding that the court correctly determined that the officers' warrantless entry into Smallfoot's residence pursuant to the consent of another alleged resident of the home was constitutionally permissible.

Following a jury trial, Appellant Lawrence Silva was convicted for aggravated burglary and attempt to commit kidnapping. The district court sentenced Appellant to imprisonment for twelve to fifteen years on each count to be served concurrent. The Supreme Court affirmed the convictions and sentences, holding (1) the district court did not err by preventing Appellant from introducing certain evidence of the victim's previous sexual conduct, as the evidence was irrelevant to Appellant's defense; and (2) the district court properly declined to instruct the jury on the offense of false imprisonment as a lesser-included offense of kidnapping because the lesser-included offense required an element not required for the higher felony offense.

Gary James was convicted of two counts of aggravated assault and battery and two counts of driving under the influence with serious bodily injury. The district court imposed four consecutive terms of eight to ten years of incarceration. James appealed, contending that the convictions should have merged to two convictions for sentencing purposes because the consecutive sentences violated his constitutional right against multiple punishments for the same offense. The Supreme Court affirmed, holding that because James committed two separate and distinct criminal acts against each of two victims, the district court appropriately imposed consecutive sentences for those separate offenses.

Appellant received a sentence of twenty to twenty-two years imprisonment for a crime punishable by a term of twenty years to life. More than four years after starting his sentence, Appellant filed a motion to correct an illegal sentence, alleging that his sentenced violated Wyo. Stat. Ann. 7-13-201 because the minimum term was greater than ninety percent of the maximum term. Rather than decrease the minimum term below the statutory minimum, the district court increased the maximum term from 265 months to 267 months. Appellant appealed, arguing that increasing his sentence after he had begun to serve that sentence violated double jeopardy. The Supreme Court affirmed, holding (1) Appellant's original sentence was illegal because it violated the statutory requirement that a minimum term may not be more than ninety percent of the maximum term; (2) the district court correctly increased the maximum term; but (3) the corrected sentence should have reflected the appropriate credit for the time appellant had served. Remanded.

Brady Michaels was arrested for driving while under the influence of alcohol. The Department of Transportation (the State) notified him that it was suspending his driver's license for ninety days. The Office of administrative Hearings (OAH) upheld the suspension. The district court affirmed. The Supreme Court affirmed the district court's order upholding the license suspension, holding (1) the OAH's ruling that Wyo. Stat. Ann. 31-5-233(b) (the statute) does not distinguish between alcohol concentration caused by consuming alcoholic beverages and alcohol concentration caused by some other factor was incorrect, as the statute was intended to apply when a person drives or is in actual control of a motor vehicle after consuming alcohol beyond the legal limit or to a degree rendering him incapable of safely driving; but (2) the State met its burden of proving that probable cause existed at the time of the arrest to believe that Michaels had violated the statute.

The district court terminated Father's parental rights to his three children after finding by clear and convincing evidence that he was incarcerated for a felony conviction and was unfit to have the custody and control of the children. The Supreme Court affirmed, holding (1) the district court did not plainly err when it allowed a police report and the testimony of the officer who wrote the report into evidence; (2) the district court did not plainly err when it allowed into evidence the officer's testimony regarding the credibility of a victim's statement; and (3) Mother presented clear and convincing evidence that Father was unfit to have the custody and control of his children.

Appellees, Shari and Steve Skaj, brought suit against Appellant Vincent Rosty to recover damages caused when an idling dump truck that had been driven by Appellant was knocked into gear, pinning Shari against a motor home. Appellant failed to plead or otherwise defend against the allegations in the complaint. The district court subsequently entered default judgment against Appellant and awarded damages to Appellees. The court then denied Appellant's motion to set aside entry of default or for relief from default judgment. On appeal, the Supreme Court affirmed in part and reversed in part, holding (1) Appellant's appeal was timely; (2) the district court did not violate Appellant's due process rights, as Appellant had adequate notice of the default judgment hearing and thus had a meaningful opportunity to be heard at the hearing; (3) Appellant was properly served with the summons and complaint; (4) the district court did not abuse its discretion by denying Appellant's motion to set aside entry of default and default judgment; and (5) the district court abused its discretion in awarding punitive damages, as Appellees failed to produce sufficient evidence of Appellant's wealth or financial condition to support an award of punitive damages. Remanded.

After initiating a traffic stop, a highway patrol trooper found marijuana in Jason Holohan's vehicle. Holohan was charged with two counts of possession of a controlled substance with intent to deliver. Holohan filed a motion to suppress the evidence seized during the search of his vehicle, claiming the trooper lacked probable cause or reasonable suspicion to justify the traffic stop at the time he activated his flashing lights and could not use events occurring after activating his lights to justify the stop. The district court agreed and granted the motion. The Supreme Court reversed, holding (1) because Holohan did not submit to the trooper's show of authority in activating his lights, there was no Fourth Amendment seizure until the vehicle pulled off the highway and stopped; and (2) at the point that the vehicle pulled off the highway, the trooper had probable cause to stop the vehicle for weaving erratically and a reasonable suspicion of criminal activity based upon Holohan's failure to pull over in response to the flashing lights.

Decedent died, leaving a house. A developer who claimed to have purchased the property from Decedent's daughter filed a petition for probate without administration of an alleged will of Decedent. Decedent's neighbors filed a petition to revoke the probate of the will, alleging that the will was invalid and that the probate court improperly admitted the will to probate. Decedent's son filed a motion to intervene and join as a petitioner seeking to revoke the probate. The probate court (1) concluded that it did not have jurisdiction to hear the neighbors' petition to revoke because they lacked standing; (2) granted the developer's motion to dismiss the petition to revoke the will; and (3) found that because the son, who did have standing, did not file his own motion challenging the will, the court's jurisdiction was not properly invoked. The Supreme Court reversed, holding (1) the son's pleading, in essence, was a petition to revoke, and it should have been treated as such; (2) the district court should have allowed intervention under the circumstances presented here; and (3) substitution of the son as the real party in interest should have been allowed in this case. Remanded.

Appellant Roger Snow was convicted of felony burglary and a related misdemeanor. Snow appealed, contending that the district court erred when it denied his request for a new attorney and that he received ineffective assistance of counsel. The Supreme Court affirmed, holding (1) the district court met its obligation to inquire about Snow's request for substitute counsel, and therefore the court did not abuse its discretion in addressing Snow's desire for substitute counsel; and (2) Snow failed to show he was entitled to a lesser-included offense instruction, or that his attorney's failure to request such an instruction so prejudiced him as to require reversal.