Brown v. State — Drug convictions and 30-to-40-year sentence affirmed
The Wyoming Supreme Court held that Brown waived a new dog-sniff suppression theory and upheld the admission of coded drug-related messages under Rule 404(b).
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Criminal Procedure
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Daniels v. State — Wyoming Supreme Court Rejects Ineffective-Assistance Bid
The Wyoming Supreme Court affirmed the denial of a new trial because substantial independent evidence defeated prejudice from counsel’s alleged errors.
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Marler v. State — Wyoming Supreme Court Affirms Sexual Abuse Convictions, Upholds Broad Rule 404(b) Admission of Grooming and Discipline Evidence
The Wyoming Supreme Court affirmed Steven Randall Marler’s convictions on eight counts of sexual abuse and six counts of battery against children in his care, holding that the district court properly admitted broad Rule 404(b) “other acts” evidence of grooming rituals and a fear-based disciplinary regimen, that a victim’s collateral lie to a jail guard was excludable without violating the Confrontation Clause, that a rule-of-completeness claim was waived by failure to make an offer of proof, and that brief prosecutorial questioning about a victim’s father’s suicide did not constitute plain-error misconduct.
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Hughes v. State — Plea Agreement “Sentencing Cap” Is a Non-Binding Recommendation, Not a Stipulated Sentence Under W.R.Cr.P. 11(e)(1)(C)
The Wyoming Supreme Court unanimously affirmed consecutive sentences for a former Casper police officer who pleaded guilty to five counts of aggravated assault and battery following a prolonged armed standoff, holding that a plea agreement capping the State’s “sentencing argument” was a non-binding recommendation under W.R.Cr.P. 11(e)(1)(B)—not a stipulated sentence under 11(e)(1)(C)—and that Wyoming district courts need not make specific findings when deviating from a sentencing recommendation.