Willis v. State

Summary

The Supreme Court of Wyoming affirmed Franklin S. Willis's conviction for felony larceny by a bailee arising from his sale of three horses entrusted to his care. The court held that sufficient evidence supported the jury's findings regarding bailment, intent, and the value of the property. It also rejected challenges to hearsay impeachment, exclusion of a registration certificate, and cumulative error.

Holdings

1. The evidence was sufficient for a rational jury to find beyond a reasonable doubt that Willis was entrusted with the horses, intended to steal or deprive Sondeno of her ownership interest, converted the horses by selling them, and that the value converted was at least $500.
2. The trial court did not abuse its discretion by allowing the State to impeach its own witness with extrinsic evidence of the witness's prior inconsistent statement after the witness had an opportunity to explain or deny the statement and the defense had an opportunity to cross-examine.
3. The trial court did not clearly abuse its discretion by excluding the 1989 ownership certificate because it did not concern the horses underlying the conviction and was too remote in time, intent, and legal effect to make the charged ownership transfer more probable.
4. The cumulative-error claim failed because the court found no error in the challenged rulings.

Questions Presented

1. Whether sufficient evidence supported Willis's conviction for felony larceny by a bailee, including evidence of a felonious taking, bailee status, intent to steal or deprive the owner, conversion, and property value of at least $500.
2. Whether the trial court violated Willis's right to a fair trial by excluding evidence offered to support his claimed good-faith belief that Sondeno had given him ownership of the horses.
3. Whether the trial court erred by admitting testimony concerning a prior inconsistent statement to impeach the State's own witness.
4. Whether the trial court abused its discretion by excluding a Jockey Club ownership certificate as irrelevant.
5. Whether cumulative error deprived Willis of a fair trial.

Disposition

affirmed