Harris v. State

Summary

The Wyoming Supreme Court held that a muzzle-loading black powder rifle qualifies as a firearm under Wyo. Stat. Ann. § 6-8-102, which prohibits an unpardoned violent felon from possessing any firearm. The court rejected the defendant's facial and as-applied vagueness challenges and concluded that his belief that possession was lawful was a mistake of law, not a defense to the general-intent crime. The court affirmed the denial of the motion to dismiss and the exclusion of related evidence.

Holdings

1. A muzzle-loading black powder rifle falls within the term firearm in § 6-8-102 because the ordinary meaning of firearm includes a weapon capable of firing a projectile by means of an explosive propellant, and the statute applies to any firearm without creating an exception for muzzle-loading rifles.
2. Section 6-8-102 is not unconstitutionally vague on its face or as applied to Harris.
3. The district court properly excluded evidence of Harris's belief that possession of the rifle was lawful because the charged offense is a general-intent crime and a mistake of law is not a defense.

Questions Presented

1. Whether a muzzle-loading black powder rifle is a firearm under Wyo. Stat. Ann. § 6-8-102.
2. Whether § 6-8-102 is unconstitutionally vague on its face or as applied because it does not define firearm.
3. Whether the district court erred by excluding evidence of Harris's belief that possession of the rifle was lawful.

Disposition

affirmed