Tilley v. State, 2011 WY 153

Summary

The Wyoming Supreme Court affirmed Marvin Tilley's convictions for six counts of sexual assault and one count of aggravated burglary. The court held that the evidence, including testimony concerning assaults occurring years earlier and testimony from victims whose recollections lacked precise dates, was sufficient for a jury to find each element beyond a reasonable doubt. The court also rejected Tilley's arguments concerning delayed reporting, lack of corroboration, and conflicting testimony.

Holdings

1. The State presented sufficient evidence for a reasonable jury to find beyond a reasonable doubt that Tilley committed the charged sexual assaults and aggravated burglary; the convictions were therefore affirmed.
2. The inability of victims to identify precise dates did not require reversal where the evidence placed the offenses within the periods charged and the defendant did not challenge the charging documents for lack of notice.
3. The lengthy delay before prosecution and the absence of corroborating evidence did not make the convictions legally insufficient; witness credibility and the weight of the evidence were matters for the jury, and Wyoming law does not require corroboration of a sexual-assault victim's testimony.

Questions Presented

1. Whether the evidence was sufficient to support Tilley's six sexual-assault-related convictions and aggravated-burglary conviction.
2. Whether the victims' inability to identify precise dates for some offenses rendered the evidence insufficient.
3. Whether the passage of many years before prosecution and the lack of corroboration for some victims' testimony required reversal under the beyond-a-reasonable-doubt standard.

Disposition

affirmed