Constitutional Cases
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Constitutional

Wyoming Supreme Court
Uncategorized

Campbell v. State — Totality of Circumstances, Not Paragraph-by-Paragraph Scrutiny, Controls Probable Cause Review

The Wyoming Supreme Court unanimously affirmed the denial of Christopher Campbell’s motion to suppress evidence seized from his Evanston residence, holding that Deputy Barker’s search-warrant affidavit established probable cause under the totality-of-circumstances test. The court rejected Campbell’s paragraph-by-paragraph critique of the affidavit as methodologically improper: Wyoming law requires courts to evaluate the affidavit as a whole, not in piecemeal fashion. Viewed in its totality, a convergence of circumstantial links—a matching U-Haul seen at the residence, receipts tying an associate to both the truck and the address, Arizona connections shared by the stolen vehicle and the occupants, and matching tire tracks—established the required nexus between the evidence sought and the place to be searched.

Wyoming Supreme Court
Uncategorized

Allen v. State — Guilty Plea Does Not Waive Challenge to Court-Ordered Asset Sale Securing Public Defender Fees

The Wyoming Supreme Court reversed and remanded a criminal case in which the district court ordered the defendant to sell a vehicle and deposit the proceeds as a condition of maintaining his public defender appointment. The court held that the subsequent guilty plea did not waive the challenge because the issue was unrelated to guilt or conviction, and that the district court exceeded its statutory authority under Wyoming’s public defender reimbursement statute by compelling a pre-sentencing forced asset liquidation.

Wyoming Supreme Court
Uncategorized

In re: AC and BI — Juvenile Court’s Mid-Hearing Cure Satisfies Due Process When Pro Se Parent Declines Opportunity to Cross-Examine

The Wyoming Supreme Court affirmed a child neglect adjudication under plain-error review, holding that a juvenile court’s failure to invite a pro se mother to present opening and closing statements or to cross-examine witnesses was cured mid-hearing when the court three times offered her the opportunity to recall and question any witness—an opportunity she declined.

Wyoming Supreme Court
Uncategorized

Manders v. State — Castle Doctrine Presumptions Do Not Extend to Driveway or Yard; Self-Defense Immunity Denied Where Victim Was Never Entering the Home

The Wyoming Supreme Court affirmed the denial of self-defense immunity to a man who shot and killed his neighbor during a dispute over property boundaries, holding that Wyoming’s castle doctrine presumptions under § 6-2-602(b) and (d) do not extend to outdoor areas such as driveways, and that a defendant’s subjective belief that an intruder was about to enter his home — without objective corroboration — is insufficient to trigger the statutory presumptions.

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