Summary
The Supreme Court of Wyoming reviewed Michael Dale Iseli's convictions for interference with a peace officer and causing bodily injury to a peace officer. The court held that the jury instructions accurately stated the elements of the offense, adequately presented Iseli's theory of defense, and properly omitted the proposed self-defense instructions. The convictions were affirmed.
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Practice areas
Questions Presented
- Whether the district court properly instructed the jury on the elements of causing bodily injury to a peace officer under Wyo. Stat. Ann. § 6-5-204(b), including the defendant's claimed lack of knowledge that Davis was a peace officer.
- Whether the district court improperly refused to give Iseli's proposed theory-of-defense instruction.
- Whether the district court improperly refused to give Iseli's proposed self-defense instructions.
Holdings
- The district court did not abuse its discretion by giving an elements instruction requiring proof that Iseli intentionally and knowingly caused bodily injury to a peace officer while the officer was lawfully performing official duties, together with a separate theory-of-defense instruction addressing Iseli's claim that he did not know Davis was a peace officer.
- The district court did not abuse its discretion by refusing the proposed theory-of-defense instruction because the instructions given adequately presented Iseli's defense that he did not know Davis was a peace officer.
- The district court properly refused the proposed self-defense instructions because self-defense was unavailable if Iseli knew Davis was a peace officer, Iseli could not be guilty of the charged offense if he genuinely lacked the required knowledge, and there was no evidence that the officers used excessive force.
Key quotations
“Instructions must be considered as a whole, and individual instructions, or parts of them, should not be singled out and considered in isolation.” (¶ 9)
“If the appellant knew Davis was a peace officer, he had no right to defend himself against arrest, so no self-defense instruction was warranted. If the appellant did not know Davis was a peace officer, he cannot be guilty of the charged crime, so no self-defense instruction was warranted.” (¶ 18)
Factual background
Law-enforcement officers located Iseli at a park to arrest him on outstanding felony warrants. Investigator Davis, who was in civilian clothing but identified himself as a deputy sheriff and stated that he had an arrest warrant, pursued Iseli after Iseli ran and resisted arrest. During the ensuing struggle, Iseli struck Davis and grabbed his throat; Davis struck Iseli with his pistol, after which Iseli continued attempting to flee and resist arrest until officers subdued and handcuffed him.
Procedural history
Iseli was charged under Wyo. Stat. Ann. § 6-5-204(a) and (b), tried before a jury, and convicted. The Wyoming Supreme Court reviewed the district court's refusal to give several proposed elements, theory-of-defense, and self-defense instructions.