Justia Civil Rights Opinion Summaries

Petitioners petitioned to be appointed permanent guardians of their elderly uncle, Thomas Lankford. The district court dismissed the guardianship petition after finding Petitioners were not qualified to serve as guardians because their potential to inherit from Lankford created a disqualifying conflict of interest. Petitioners appealed, asserting (1) the district court erred in finding a conflict of interest, and (2) in the alternative, the guardianship conflict waiver statute, which allows a court of waive conflicts but limits that authority to conflicts of a spouse, adult child, parent, or sibling of a ward, violated their due process and equal protection rights. The Supreme Court affirmed, holding (1) the district court did not err in finding a conflict of interest; and (2) Petitioners' constitutional claims were not properly before the Court. View "Utley v. Lankford" on Justia Law

Appellant was charged while driving under the influence. The Wyoming Department of Transportation suspended Appellant's driver's license. Appellant appealed, arguing that she had not been properly advised as to implied consent. The Office of Administrative Hearings upheld the suspension. Appellant sought review of the administrative suspension in the district court, raising a number of constitutional challenges to a municipal criminal ordinance in addition to the claim that she had not been properly advised under the implied consent statute. The district court concluded (1) the constitutional issues raised by Appellant had not and could have been raised in the administrative hearing, and therefore, the court lacked jurisdiction to consider the claims; and (2) Appellant was properly advised as to implied consent. The Supreme Court affirmed, holding (1) the hearing officer correctly determined that Appellant was properly advised as required by statute; and (2) Appellant's other claims were not and could have been presented in a license suspension proceeding. View "Walters v. State ex rel. Wyo. Dep't of Transp." on Justia Law

After a jury trial, Appellant was convicted of felony stalking. Appellant appealed, contending (1) the amended information did not allege sufficient facts to constitute the offense of felony stalking and did not adequately inform him of the charges against him; and (2) the jury was not adequately instructed with respect to the intent element of the crime. The Supreme Court reversed and remanded for a new trial, holding (1) the district court did not err in permitting the State to amend the information; (2) Appellant was not denied his constitutional right to adequate notice of the charge he was required to defend against; but (3) the district court plainly erred by providing a confusing and misleading jury instruction that combined two of the elements of stalking, and the error in the jury instructions caused prejudice to Appellant. View "Walker v. State" on Justia Law

Appellant pled guilty to attempted second degree murder in an oral plea agreement and was sentenced to a term of twenty-five to fifty years in prison. The district court also awarded restitution. Appellant later removed to withdraw his plea, claiming that his attorney conspired with the court, misled him about the term he would serve, and coerced him into pleading guilty. The district court denied the motion, concluding that Appellant failed to demonstrate manifest injustice. Appellant appealed, claiming the district court abused its discretion in denying his motion to withdraw his guilty plea and in awarding restitution. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it denied Appellant's motion to withdraw his guilty plea; and (2) the district court had authority to award restitution and to waive public defender fees. View "Chapman v. State" on Justia Law

After a jury trial, Defendant was found guilty of aggravated assault and battery. The jury found Defendant guilty of threatening to use a drawn deadly weapon on another person, which was one of the State's two theories it advanced that Defendant committed aggravated assault. Defendant filed a motion for a new trial because the district court failed to instruct the jury that he had no duty to retreat before "threatening to use a drawn deadly weapon." The district court denied the motion and sentenced Defendant. The Supreme Court affirmed, holding that the jury instructions at issue did not violate a clear and unequivocal rule of law, and therefore, Defendant failed to establish plain error in the district court's denial of Defendant's motion for a new trial. View "Mendoza v. State" on Justia Law

Defendant pleaded guilty to one count of larceny. Defendant appealed, claiming that the factual basis provided by the State for his guilty plea was inadequate as a matter of law because it did not establish the "taking" element of the crime of larceny. The State argued that the factual basis was sufficient because Defendant entered a voluntary plea and the facts established that he committed some crime even though the elements of the larceny statute were not satisfied. The Supreme Court reversed, holding that the district court committed plain error by entering judgment on Defendant's guilty plea when it was not supported by a sufficient factual basis. View "Nguyen v. State" on Justia Law

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