Benjamin v. State

Summary

The Supreme Court of Wyoming affirmed Leah D. Benjamin's conviction for second-degree murder in the shooting death of her estranged husband. The court rejected challenges concerning juror implied bias, proposed jury instructions based on the Eagan Rule, and the denial of a post-trial motion for judgment of acquittal; the provided text ends before the court's discussion of the self-defense issue is complete.

Holdings

1. The district court did not abuse its discretion by denying Benjamin's late request to remove juror Blaney. Benjamin waived any objection to Blaney's service during voir dire, and the circumstances observed during trial did not sufficiently change to require reconsideration of that waiver.
2. The district court properly refused Benjamin's proposed instructions stating that a defendant's testimony as the sole witness to the charged transaction must be accepted under specified circumstances. The Eagan Rule did not apply because Benjamin's credibility had been impeached and her testimony was inconsistent with physical evidence.
3. The district court properly denied Benjamin's motion for judgment of acquittal because the State presented sufficient evidence from which a reasonable jury could find beyond a reasonable doubt that Benjamin did not act in self-defense.
4. The alleged prosecutorial comments during voir dire, opening statement, and closing argument did not constitute reversible prosecutorial misconduct. The preserved comments were harmless, and the unpreserved claims did not satisfy plain-error review.

Questions Presented

1. Whether the district court erred by denying Benjamin's late request to remove juror Blaney, who was married to a prosecution consultant.
2. Whether the district court erred by refusing Benjamin's proposed jury instructions based on the Eagan Rule concerning the testimony of an accused who is the sole eyewitness.
3. Whether the evidence was insufficient to disprove self-defense and required judgment of acquittal under W.R.Cr.P. 29(c).
4. Whether alleged prosecutorial misconduct during voir dire, opening statement, and closing argument deprived Benjamin of a fair trial or constituted reversible error.

Disposition

affirmed