Justia Civil Rights Opinion Summaries

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

Defendant pleaded guilty to driving while under the influence of alcohol (DWUI). This was Defendant’s fourth such offense within the previous ten years, making it a felony under Wyo. Stat. Ann. 31-5-233(e) and subject to a sentence enhancement. Defendant filed a motion to strike two of four prior convictions, claiming that the two prior DWUI convictions were not constitutionally obtained and therefore should not have been relied upon for sentence enhancement purposes. The district court denied Defendant’s motion, ruling that because Defendant had not appealed from his earlier convictions the convictions could not be overturned. The court then enhanced Defendant’s conviction to a felony and sentenced Defendant accordingly. The Supreme Court affirmed Defendant’s enhanced sentence, holding that Defendant’s underlying convictions were constitutionally obtained. View "Derrera v. State" on Justia Law

After a jury trial in Sweetwater County, Appellant was found guilty of third-degree sexual abuse of a minor for offenses committed against a fifteen-year-old girl on a Greyhound bus. Defendant filed a motion for judgment of acquittal, arguing that the State had not offered evidence to prove that the crime had occurred in Sweetwater County. The Supreme Court affirmed, holding (1) that prosecutor’s tactics did not amount to judge-shopping so as to deprive Appellant of his constitutional right to due process; (2) the jury was correctly instructed regarding venue; (3) the evidence established that venue in Sweetwater County was proper; and (4) the prosecutor’s misstatement of the law regarding venue in her closing argument did not constitute reversible error. View "Anderson v. State Employment Sec. Div." on Justia Law

After a jury trial, Appellant was convicted on two separate charges of delivery of a controlled substance and one charge of possession of a controlled substance. After the Supreme Court affirmed on appeal, Appellant filed a motion to correct an illegal sentence, asserting that his two convictions and sentences on two charges of delivery resulted in his being punished twice for the same offense in violation of the prohibition against double jeopardy. The district court denied the motion. The Supreme Court affirmed, holding that because Defendant committed two separate and distinct crimes on two separate dates, each charge included an element that was unique, and thus, double jeopardy did not attach. View "Mebane v. State" on Justia Law

After a jury trial, Defendant was found guilty of first degree sexual assault for forcing a young woman to perform oral sex on him. Defendant appealed, arguing that his trial counsel rendered ineffective assistance in three respects. The Supreme Court affirmed Defendant’s conviction and sentence, holding that Defendant did not prove that his counsel was constitutionally ineffective for (1) seeking to introduce evidence under Wyoming’s rape shield statute; (2) failing to investigate Defendant’s “probable level of intoxication” before an interview with law enforcement; and (3) failing to object to a statement made by the prosecutor during her rebuttal closing argument. View "McGarvey v. State" on Justia Law

In April 2011, Appellant was arrested for driving under the influence of alcohol (DUI) and pleaded guilty to DUI. The Wyoming Department of Transportation (WYDOT) did not notify Appellant until August 2012 that he would be disqualified from using his commercial driver’s license for one year and that his driver’s license would be suspended for ninety days. The Office of Administrative Hearings (OAH) upheld the suspension and disqualification. Appellant filed a petition for judicial review, challenging the proceedings instituted nearly a year and a half after his DUI conviction. The district court affirmed the OAH decisions. The Supreme Court affirmed, holding (1) the administrative proceedings were promptly instituted as required by Wyo. Stat. Ann. 16-3-113; and (2) Appellant did not establish that the delay deprived him of procedural due process. View "Dubbelde v. State ex. rel. Dep't of Transp." on Justia Law

After a jury trial, Defendant was found guilty of three counts of second-degree sexual assault. The Supreme Court affirmed, holding (1) Defendant was not denied his right to a speedy trial; (2) the district court properly admitted forensic interview evidence as a prior consistent statement; (3) the bill of particulars was sufficient for Defendant to adequately prepare a defense; (4) the circuit court committed harmless error when it granted an ex parte motion quashing Defendant’s subpoena to call the victim and her mother as witnesses at a preliminary hearing; (5) the district court did not abuse its discretion when it denied admission of sexualized behavior evidence on relevancy and hearsay grounds; and (6) the State did not commit prosecutorial misconduct when it referenced a non-religious quote from a church sign in its opening statement. View "Ortiz v. State" on Justia Law