Justia Juvenile Law Opinion Summaries

Articles Posted in Wyoming Supreme Court
by
The case revolves around Audrey Mae Lessner, who was convicted of felony child abuse under Wyo. Stat. Ann. § 6-2-503(b)(i) (2023) after a bench trial. The charges stemmed from an incident where Lessner, while babysitting an 11-year-old child identified as FF, spanked the child eleven times with a belt as punishment for lying. The spanking resulted in significant bruising on the child's thigh. Lessner appealed her conviction, arguing that the district court abused its discretion by denying her motion to continue the trial and that the State failed to present sufficient evidence to prove that she did not engage in reasonable corporal punishment.Prior to the trial in the District Court of Sweetwater County, Lessner had sought to represent herself, a request that the court granted after advising her of the risks. She later filed a motion for an extension of time, claiming that the prosecution was not assisting her in obtaining information for a subpoena. However, she later informed the court that she no longer needed an extension and was ready for trial. On the first day of the bench trial, Lessner filed a motion for an emergency hearing, asserting that she was not ready to proceed because the State was denying some discovery. The court denied her motion and proceeded with the trial.The Supreme Court of Wyoming affirmed the lower court's decision. It found that the district court did not abuse its discretion in denying Lessner's motion to continue the trial. The court also found that the State presented sufficient evidence to demonstrate that the physical injury inflicted on the child was not the result of reasonable corporal punishment. The court noted that Lessner's actions, including her decision to use a belt to avoid injuring her hand and her refusal to stop spanking the child other than to rest her arm, did not represent a method of correction but rather an adult who had lost control of her own responses. View "Lessner v. The State of Wyoming" on Justia Law

by
The case involves a mother appealing against a juvenile court's ruling that she neglected her infant son, AE. The infant was born prematurely and consistently underweight. Despite numerous hospitalizations and health professional instructions, the child's weight did not significantly increase while under the parents' care. However, the child showed substantial weight gain while hospitalized. The State filed a petition alleging that the parents neglected AE by failing to provide adequate care necessary for the child's well-being. The juvenile court ruled in favor of the State concerning the mother, but not the father, due to insufficient evidence against him.The Supreme Court of Wyoming affirmed the lower court's decision. The court found that the evidence of the child's ability to gain weight in a hospital setting versus his home was enough to support the neglect adjudication against the mother. The court stressed that although the mother followed medical instructions and took AE to medical appointments, the child's failure to thrive at home pointed to neglect. This case demonstrates that the courts assess neglect based on the child's well-being and not necessarily on the intent or efforts of the parents. View "In the Interest of A. E. v. The State of Wyoming" on Justia Law

by
The Supreme Court affirmed the judgment of the district court reducing Joshua Anderle's sentence for sexual abuse of a minor by two years following his completion of the Youthful Offender Transition Program, holding that the district court did not abuse its discretion by reducing Anderle's sentence by two years in recognition of his successful completion of the program.Anderle entered an Alford plea to second-degree sexual abuse of a minor. The district court sentenced him to eight to twelve years' imprisonment and recommended that the Wyoming Department of Corrections treat Anderle as a youthful offender under Wyo. Stat. Ann. 7-13-1001 et seq. After Anderle successfully completed the program the court held a sentence reduction hearing and reduced Anderle's sentence by two years. The Supreme Court affirmed, holding that the district court reasonably declined to reduce Anderle's sentence to probation. View "Anderle v. State" on Justia Law

by
The Supreme Court affirmed the judgment of the juvenile court placing MBP, a juvenile, on supervised probation for three to six months after adjudicating him delinquent for fighting in public, holding that the juvenile court did not err in either its adjudication or order of disposition.As part of the disposition, the juvenile court placed MBP on supervised probation for three to six months. MBP appealed, arguing that the evidence was insufficient establish to support the adjudication and that the sentence imposed was contrary to law. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the requisite intent and established an implicit agreement to fight; and (2) MBP failed to establish that the juvenile court's imposition of a three-to-six-month probationary term constituted plain error. View "MBP v. State" on Justia Law

by
The Supreme Court reversed the judgment of the juvenile court denying RH's petition for expungement of his record pursuant to Wyo. Stat. Ann. 14-6-241, holding that the district court erred in interpreting sections 14-6-241(d) and (e).When RH was sixteen years old the State filed a delinquency petition against him. RH agreed to a deferred prosecution and successfully completed the terms of his deferral. Thereafter, the juvenile court dismissed the delinquency petition. RH later petitioned for expungement of his record. The juvenile court denied the petition, concluding that RH was statutorily ineligible to have the record expunged because the petition charged him with a violent felony. The Supreme Court reversed, holding that section 14-6-241 allows expungement of a juvenile record where a delinquency petition was dismissed but the delinquent act charged was a violent felony. View "RH v. State" on Justia Law

by
The Supreme Court reversed Defendant's conviction for third-degree sexual assault and false imprisonment, holding that the district court erred in denying Defendant's motion to transfer his case to juvenile court.Defendant was eighteen years old when the State charged him with offenses that he allegedly committed when he was seventeen years old. When Defendant moved to transfer his case to juvenile court, the State argued that the juvenile court lacked concurrent jurisdiction because Defendant was an adult when the charges were filed against him. The district court dismissed Defendant's transfer motion, concluding that the juvenile court's jurisdiction depended on Defendant's age when he was charged rather than his age when he committed the offense at issue. The Supreme Court reversed, holding that a juvenile court's concurrent jurisdiction under Wyo. Stat. Ann. 14-6-203(c) depends on an offender's age at the time of the offense, rather than at the time charges are filed. View "Rosen v. State" on Justia Law

by
The Supreme Court affirmed the judgment of the district court denying Defendant's motion to transfer his case to juvenile court, holding that the district court did not abuse its discretion in denying the motion to transfer the case to juvenile court.Defendant, a minor, was arrested and charged with nine counts of attempted first-degree minor after taking guns and ammunition to his high school planning to shoot nine particular individuals and as many other people as he could. Defendant filed a motion to transfer his case to juvenile court, but the motion was denied. The Supreme Court affirmed, holding that the district court appropriately analyzed and weighed the applicable factors under Wyo. Stat. Ann. 14-6-237(b) and did not abuse its discretion in denying Defendant's motion to transfer. View "Warner v. State" on Justia Law

by
The Supreme Court reversed the district court’s denial of Defendant’s motion to modify his original sentence after a new individualized sentencing hearing and remanded for a new individualized sentencing hearing.Defendant was seventeen years old when he and his friend robbed and murdered a hitchhiker. Defendant was sentenced to life imprisonment with a consecutive twenty-to-fifty-year sentence for aggravated robbery. Following the decisions in Miller v. Alabama, 567 U.S. 460 (2012), Montgomery v. Louisiana, __ U.S. __ (2016), and Bear Cloud v. State, 294 P.3d 36 (Wyo. 2013), and the Wyoming Legislature’s amendment to Wyo. Stat. Ann. 6-10-301(c), Defendant was granted parole from his life sentence and began serving his consecutive twenty-to-fifty-year sentence. Defendant received a new individualized sentencing hearing, after which the district court declined to modify Defendant’s original sentence. The Supreme Court reversed and remanded for an additional sentencing hearing because at the time of the hearing and the district court’s decision, the parties and the district court did not have the advantage of this Court’s rulings concerning the procedure, burdens, and potentially relevant evidence for a Miller determination contained within this opinion. View "Davis v. State" on Justia Law

by
Defendant was sixteen years old when he committed the crimes at issue in this case. The Supreme Court affirmed Defendant’s convictions of one count of first-degree murder, one count of aggravated assault and battery, and ten counts of attempted aggravated assault and battery but reversed Defendant’s sentence and remanded for resentencing. The court held (1) the district court did not abuse its discretion when it denied Defendant’s motion to transfer the proceedings to juvenile court; (2) there were some errors in the jury instructions, but the errors were not prejudicial either individually or cumulatively; (3) the prosecutor’s victim impact statements during closing arguments were improper but not prejudicial; (4) there was sufficient evidence to support the attempted assault and battery charges; (5) Defendant’s aggregate sentence did not deprive the parole board of its statutory authority to consider parole of juveniles after twenty-five years; (6) Defendant’s sentence for murder and aggravated assault of the same victim did not violate double jeopardy; but (7) Defendant’s aggregate sentence violated the Eighth Amendment because it was a de facto life without parole sentence. View "Sam v. State" on Justia Law

by
Appellant was adjudicated a delinquent juvenile for committing a sexual offense that required him to register as an offender under the Wyoming Sexual Offender Registration Act (WSORA). Appellant later entered a conditional guilty plea to two felony counts for failing to report changes in his address, as required by the WSORA. Appellant appealed his convictions, claiming that the WSORA is unconstitutional. The Supreme Court affirmed, holding (1) the Wyoming Juvenile Justice Act does not conflict irreconcilably with the WSORA’s registry requirements for adjudicated juvenile offenders; (2) the WSORA does not violate the Wyoming Constitution’s equal protection clause; (3) Appellant failed to establish that the WSORA’s lifetime registration requirement violates his due process rights; and (4) the WSORA does not violate the ex post facto clause of the United States Constitution. View "Vaughn v. State" on Justia Law