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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Appellate Procedure
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Duncan v. State — Court Defines Explicit Sexual Conduct and Upholds Sentence
The Wyoming Supreme Court held that digital penetration and use of a sexual device qualify as explicit sexual conduct under the child-exploitation statute and upheld an aggregate 21-to-30-year sentence.
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Glenn — Wyoming Supreme Court Upholds Bicycle Stop and Enforces Conditional-Plea Limits
The Wyoming Supreme Court upheld a bicycle stop based on an objectively reasonable factual mistake and refused to review issues not specifically preserved in a conditional plea.
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Beedy — Wyoming Supreme Court Upholds Converse County Venue and Clothing Restitution
Wyoming’s high court held that vulnerable-adult exploitation spanning two counties could be tried in Converse County and affirmed restitution for clothing made inaccessible by the crime.
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Smith v. Wyoming — Premature Willfulness Finding in Probation Revocation Adjudicatory Phase Is Error, But Not Plain Error Without Material Prejudice
The Wyoming Supreme Court affirmed a probation revocation, holding that the district court erred by determining willfulness during the adjudicatory phase rather than the dispositional phase—a clear violation of Wyoming’s two-part revocation framework—but that the error did not constitute plain error because Smith suffered no material prejudice: he presented his willfulness arguments before the court’s finding and again at disposition, and an independently established, uncontested violation independently supported revocation.
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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.
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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.