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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Evidence
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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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Dykes Estate v. Hutton — District Court May Implicitly Deny Rule 37 Sanctions When No OSC Hearing Preceded the Motion and Bench Trial Evidence Refutes Alleged Noncompliance
The Wyoming Supreme Court affirmed a bench-trial judgment for Katya Hutton against the Estate of Robert P. Dykes, holding the district court did not abuse its discretion in implicitly denying Rule 37 sanctions—no prior order-to-show-cause hearing had been sought, the Estate declined an offered continuance, and trial testimony confirmed Hutton had produced everything in her possession—and that the court did not clearly err in finding the Estate failed to prove Hutton misappropriated condo rental income where the Marriott records it relied on were demonstrably unreliable.
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In re AC and BI — Wyoming Supreme Court Affirms Neglect Finding, Upholds Admission of Post-Removal Hair Follicle Tests
The Wyoming Supreme Court affirmed a juvenile court’s finding that Father neglected his two minor children, holding the court did not abuse its discretion in admitting hair follicle test results collected after the date of alleged neglect, because the tests covered the relevant period and any challenge to their probative force went to weight rather than admissibility.