Edwards v. State

Summary

The Wyoming Supreme Court held that the trial court improperly excluded testimony concerning the deceased passenger's prior conduct of grabbing a vehicle's steering wheel while intoxicated. The evidence was relevant to Edwards's defense that the passenger's conduct, rather than Edwards's wrongful conduct, was the proximate cause of the fatal accident, so the conviction was reversed and the case remanded.

Holdings

1. Evidence of a victim's prior conduct is relevant when the conduct bears on the defendant's alleged wrongful conduct or on whether that conduct was the proximate cause of the victim's death. The testimony that Southworth previously grabbed another driver's steering wheel under similar circumstances was crucial to Edwards's causation defense and was improperly excluded.
2. The district court abused its discretion by excluding Demel's testimony concerning Southworth's prior steering-wheel interference.

Questions Presented

1. Whether the district court erred by excluding testimony that the victim previously grabbed a driver's steering wheel under similar circumstances, where the evidence was offered to support Edwards's defense that the victim caused the accident.
2. Whether the excluded evidence was relevant and admissible under Wyoming Rules of Evidence 404 and 403.

Disposition

reversed_and_remanded