Justia Civil Rights Opinion Summaries

Articles Posted in Wyoming Supreme Court
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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence seized from his home, holding that the district court did not err when it concluded that the warrantless search of Defendant's home was constitutional under the emergency aid exception to the Fourth Amendment's warrant requirement. After the district court denied his suppression motion, Defendant entered a conditional guilty plea to various drug crimes, including possession of marijuana with intent to deliver, possession of methamphetamine, and possession of marijuana. Defendant appealed the denial of his motion to suppress. The Supreme Court affirmed, holding that intrusion into Defendant's home was lawful and justified by the emergency aid exception to the Fourth Amendment's warrant requirement. View "Ferch v. State" on Justia Law

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The Supreme Court reversed the judgment of the district court forfeiting $470,040 in United States currency seized from Robert Miller to the State under the Wyoming Controlled Substances Act, Wyo. Stat. Ann. 35-7-1001 to -1060, holding that the State unreasonably delayed filing the action. Miller filed a motion to dismiss the case on grounds that the State's 270-day delay in instituting proceedings violated the statutory requirement that the State institute such proceedings "promptly" and his due process rights under the United States Constitution. The district court denied the motion and forfeited the currency to the State. The Supreme Court applied the four-factor balancing test from Barker v. Wingo, 407 U.S. 514 (1972), to assess whether Miller's right to due process had been violated. The Court then reversed and remanded for dismissal with prejudice, holding that the State failed "promptly" to institute the forfeiture proceedings, in violation of section 35-7-1049(c) and Miller's right to due process under the federal Constitution. View "Miller v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of two counts of sexual intrusion on a victim under Wyo. Stat. Ann. 6-2-314(a)(i), holding that the district court did not err when it admitted testimony under Wyo. R. Evid. 404(b) and 801(d)(1)(B) and did not violate Defendant's rights under the Confrontation Clause when it allowed the State to amend the felony information after the State had presented its witnesses. Specifically, the Supreme Court held (1) the district court did not abuse its discretion in admitting evidence of other acts under Rule 404(b) or in allowing the victim's prior consistent statements under Rule 801(d)(1)(B); and (2) the amendment to the felony information without a continuance did not deny Defendant his right to effectively cross-examine the witnesses or prejudice his defense. View "LaJeunesse v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court dismissing Appellant's declaratory judgment action arguing that the Office of Administrative Hearings (OAH), and therefore the district court on appeal, did not have jurisdiction to decide his claim that a policy officer violated his due process right to an independent blood test, holding that the district court did not abuse its discretion in dismissing the declaratory judgment action. A police officer arrested Appellant for driving under the influence of alcohol. After an officer performed a chemical breath test, Appellant was issued a suspension order for his driver's license. Appellant requested a contested case hearing, arguing that the officer denied him the statutory ability to obtain a blood test at his own expense. The OAH upheld the suspension order, finding that the officer did not deprive Appellant of his right to an independent blood test. Appellant appealed and filed a separate declaratory judgment action seeking a declaration that law enforcement violated his statutory and substantive due process rights to independent testing. The district court dismissed the declaratory judgment action. The Supreme Court affirmed, holding (1) the OAH had jurisdiction over Appellant's administrative proceeding; and (2) the district court did not abuse its discretion in dismissing the declaratory judgment action. View "Johnson v. State ex rel., Wyoming Department of Transportation" on Justia Law

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The Supreme Court reversed the judgment of the district court convicting Defendant of two counts of possession with intent to deliver a controlled substance and one count of interference with a peace officer, holding that Defendant's trial counsel provided ineffective assistance by failing to challenge the extension of Defendant's traffic stop. The traffic stop in this case led to the discovery of drugs and drug paraphernalia in Defendant's vehicle. Defendant filed a motion to suppress, arguing that the initial stop was not supported by reasonable suspicion. The district court denied the motion. On appeal, Defendant argued, among other things, that his trial counsel provided ineffective assistance by failing to challenge the duration of the traffic stop in his motion to suppress. The Supreme Court reversed and remanded the case, holding (1) Wyo. R. Crim. P. 12(b) precluded plain error review of the issues not raised in Defendant's motion to suppress evidence; and (2) Defendant showed a reasonable probability that, but for counsel's failure to challenge the duration of the stop and the actions of law enforcement officers during the stop, the outcome of the trial would have been different. View "Mills v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of two counts of operating a vehicle while under the influence of alcohol pursuant to Wyo. Stat. Ann. 31-5-233(b)(i) and (b)(iii), holding that the district court did not abuse its discretion when it admitted evidence of Defendant's blood alcohol concentration (BAC) and that Defendant was not denied due process or an opportunity to conduct an effective cross-examination at trial. On appeal, Defendant argued that the trial court erred by admitting his BAC because the State failed to establish that his blood analysis was performed according to methods approved by the Wyoming Department of Health and that the error was prejudicial. The Supreme Court affirmed, holding (1) the district court should have compelled production of a linearity study related to the calibrator for Defendant's blood samples test, but the error was harmless; and (2) Defendant was not denied his constitutional right to due process or an opportunity to confront the State's witnesses. View "Hardman v. State" on Justia Law

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The Supreme Court affirmed Defendant's convictions of aggravated assault and battery, domestic battery, strangulation of a household member, violating a protective order, and witness intimidation, holding that there was one trial error in a single incident of prosecutorial misconduct, but Defendant suffered no prejudice from the comment. Specifically, the Court held (1) the district court did not err in denying Defendant's motion for a new trial based on the State's alleged failure to disclose exculpatory evidence; (2) the district court did not err in denying Defendant's motion for a new trial based on claims of ineffective assistance of counsel; (3) the State committed prosecutorial misconduct by vouching for the credibility of the victim, but the comment was not prejudicial; (4) the district court did not err in joining charges against Defendant for trial; (5) the district court did not err in denying Defendant's motion for a Daubert hearing on the testimony of the State's domestic violence expert; and (6) cumulative error did not warrant reversal of Defendant's conviction. View "Byerly v. State" on Justia Law

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The Supreme Court affirmed the district court's denial of Defendant's motion to suppress evidence obtained after a search of his camper, holding that the search warrant contained sufficient untainted evidence to establish probable cause to search the camper. Defendant was charged with possession with intent to deliver a controlled substance and possession of a controlled substance. Defendant filed a motion to suppress, challenging the reasonableness of a search on September 8, 2017 and the probable cause for search warrants issued on September 9, 2017 and September 12, 2017. The district court denied the motion to suppress, and Defendant entered a conditional guilty plea to possession of a controlled substance. The Supreme Court affirmed, holding (1) Defendant's guilty plea did not preserve a Franks argument; and (2) even assuming the law enforcement officer unconstitutionally searched the camper when he opened plastic covering to look through a window on September 8, the warrant affidavit established probable cause through evidence attributable to the officer's unchallenged look through another window. View "Workman v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained from the search of Defendant's vehicle, holding that the law enforcement officer did not violate Defendant's Fourth Amendment rights by detaining him for a drug-dog sniff of his vehicle. Defendant pleaded guilty to possession of more than three ounces of marijuana. Defendant verbally reserved the right to appeal the district court's denial of his motion to suppress. The Supreme Court affirmed the denial of Defendant's motion to suppress, holding (1) while conditional plea agreements are typically required, under the unique circumstances of this case this Court exercises its discretion to review the verbally-reserved issue; and (2) Defendant was not seized in violation of the Fourth Amendment when the officer stopped him for following another vehicle too closely, and Defendant had reasonable suspicion justifying detaining Defendant for a drug-dog sniff of the vehicle. View "Robinson v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of attempted sexual abuse of a minor in the second degree, holding that errors in the jury instructions and any deficiencies in defense counsel's performance associated with the instructions were not prejudicial. Specifically, the Court held (1) the evidence presented at trial was sufficient to convict Defendant of attempted sexual abuse of a minor in the second degree; (2) the jury instructions on the elements of attempted sexual abuse of a minor in the second degree were incorrect; (3) it was unnecessary to discuss in detail whether defense counsel's performance in addressing the jury instructions was deficient; and (4) Defendant was not prejudiced by incorrect jury instructions and/or his counsel's deficient performance because the State presented overwhelming showing Defendant was guilty of the crime. View "Weston v. State" on Justia Law