Justia Civil Rights Opinion Summaries

Pursuant to a plea agreement, Defendant pled guilty to one count of first-degree sexual abuse of a minor. Defendant later filed a motion for sentence modification or reduction under newly discovered evidence arguing that his guilty plea was involuntary and that his trial counsel provided ineffective assistance. The district court construed the motion as both a motion to withdraw Defendant’s guilty plea and to reduce Defendant’s sentence. The district court denied the request to withdraw Defendant’s guilty plea, concluding that Defendant failed to establish newly discovered evidence resulting in manifest injustice, and concluded that it did not have jurisdiction to consider a sentence reduction because Defendant’s motion was untimely. Defendant appealed. The Supreme Court dismissed the appeal, holding that the district court did not have jurisdiction to rule on Defendant’s motion, and therefore, this Court did not have jurisdiction to consider Defendant’s appeal. View "Shue v. State" on Justia Law

Appellant filed a 42 U.S.C. 1983 civil rights action in the district court asserting four federal constitutional claims and one state law claim, alleging that, while he was an inmate in the state of Wyoming under the supervision and control of the Wyoming Department of Corrections (DOC), he was deprived of his personal property, which violated his right to due process and caused him injury. The district court granted summary judgment on all claims for the DOC. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of the DOC. View "Chapman v. Wyo. Dep’t of Corr." on Justia Law

Appellant, an inmate at the Wyoming Medium Correctional Institution, filed a petition for declaratory judgment asking the district court to find that Steve Hargett, the warden of the institution, and Robert Lampert, the director of the Department Prison Division, violated the Wyoming Public Records Act (WPRA) by delaying the production of a record he had requested under the WPRA. Appellant also asked the district court to declare that the Department of Corrections had to produce certain types of records if he requested them in the future. After Appellants filed a motion to dismiss, Appellant filed a motion to amend his petition. The district court dismissed the petition, finding that it did not have jurisdiction under the WPRA to provide the relief Appellant was seeking. The district court did not expressly rule on the motion to amend. The Supreme Court affirmed, holding (1) the district court properly dismissed Appellant’s petition because the relief Appellant sought was not available under the WPRA; and (2) the district court did not abuse its discretion by implicitly denying the motion to amend, as the proposed amendment was futile. View "Guy v. Lampert" on Justia Law

After a jury trial, Defendant was found guilty of domestic battery and possession of a weapon with intent to threaten. Defendant appealed, arguing (1) the prosecutor improperly asked him a series of questions during his testimony at trial in which the prosecutor repeated statements made by Defendant’s daughter and asked, “was she lying?”; and (2) the district court abused its discretion when it allowed evidence of prior discharge of a gun. The Supreme Court reversed, holding (1) the prosecutor’s questioning was improper, and the error was prejudicial; and (2) the absence of appropriate findings and discussion regarding the admission of the discharge evidence hinders review of the district court’s decision to admit the evidence. Remanded. View "McGinn v. State" on Justia Law

A highway patrol trooper pulled over the driver of a vehicle for following too closely and for having a cracked windshield. Appellant was seated in the front passenger seat. After Appellant appeared to have suffered a seizure, the trooper searched the pocket of Appellant’s jacket, which Appellant had left in the car, and discovered marijuana. Appellant moved to suppress the evidence found by the trooper during his search of the jacket and the vehicle. The district court denied the motion. Thereafter, Appellant entered a conditional guilty plea to one count of possession of a controlled substance. The Supreme Court affirmed the denial of Appellant’s motion to suppress, holding (1) the initial stop of the vehicle in which Appellant was a passenger was justified because the trooper had reasonable suspicion that the driver was breaking the law; and (2) the subsequent search of Appellant’s jacket was supported by the community caretaker exception to the warrant requirement and thus did not violate the Fourth Amendment. View "Allgier v. State" on Justia Law

Appellant was convicted after a jury trial of aggravated battery stemming from an altercation with his girlfriend and his girlfriend’s sister. The Supreme Court affirmed, holding (1) there was sufficient evidence to establish that the victim suffered serious bodily injury, and therefore, the jury could have determined beyond a reasonable doubt that Appellant was guilty of the crime for which he was convicted; (2) the district court did not commit plain error when it instructed the jury on the theory of self-defense; and (3) the prosecutor’s statements throughout trial were clearly improper, but Appellant was not materially prejudiced as a result of the prosecutor’s misconduct. View "Brown v. State" on Justia Law

A defendant was charged with sexual assault of a minor in connection with an AMBER Alert and a missing child. The deputy county attorney requested that the circuit court restrict disclosure of information of the case in accordance with Wyo. Stat. Ann. 6-2-319(a). The circuit court granted the request and sealed the court file and barred news organizations (Appellees) from attending any court proceedings. Appellees moved to intervene to gain access to information pertaining to the case, but the defendant was bound over to the district court before the circuit court ruled on the motion. Appellees filed a declaratory judgment action in the district court seeking a ruling on whether section 6-2-319(a) required the closure of records and proceedings in cases alleging sexual assault. The district court granted summary judgment for Appellees. The Supreme Court affirmed, holding that the circuit court (1) violated the First Amendment when it closed the court proceedings and sealed the court records; and (2) incorrectly interpreted section 6-2-319(a) when it determined that the statute required the court to seal the criminal case file and close all proceedings held in its courtroom without a hearing or findings on the record. View "Circuit Court v. Lee Newspapers" on Justia Law

Defendant, a resident alien who was living in the United States legally, pled guilty to the charge of strangulation of a household member. Before Defendant was sentenced, he learned that his guilty plea would result in his deportation. Defendant subsequently moved to withdraw the plea, arguing that his counsel’s performance was deficient. The district court determined that Defendant had succeeded in demonstrating that his counsel’s performance was deficient, but nonetheless denied Defendant’s request to withdraw his plea, concluding that Defendant failed to prove that he was prejudiced by his counsel’s failure to advise him of the possibility of deportation. The Supreme Court reversed, holding that, because of the exceptional circumstances of Defendant’s counsel’s failure to advise Defendant of his assured deportation, Defendant’s counsel provided ineffective assistance, and, therefore, there was a fair and just reason to allow Defendant to withdraw his guilty plea. View "Ortega-Araiza v. State" on Justia Law

Defendant pled guilty to one count of solicitation to commit property destruction. On appeal, Defendant argued (1) the district court lacked subject matter jurisdiction because he was in West Virginia at the time of the alleged solicitation, and (2) he received ineffective assistance of counsel. The Supreme Court affirmed, holding (1) the State had subject matter jurisdiction to prosecute Appellant for charges specified in the charging Information, as Defendant intended his criminal actions to have an effect in Wyoming; and (2) Appellant failed to carry his burden of showing that his representation by trial counsel was so ineffective that it rendered Appellant’s guilty plea involuntary. View "Turner v. State" on Justia Law

Defendant entered a conditional Alford plea to possession of a controlled substance. On appeal, Defendant challenged the district court’s denial of her motion to suppress evidence, arguing that she should have been permitted to leave the scene of a traffic stop when she asked to leave, that the arresting officer lacked reasonable suspicion to detain her, and that she should have been read her Miranda rights. The Supreme Court affirmed, holding (1) law enforcement had reasonable, articulable suspicion on which to detain Defendant; and (2) under the circumstances of this case, Defendant was not entitled to receive Miranda rights. View "Engdahl v. State" on Justia Law