Washington v. State

Summary

The Wyoming Supreme Court affirmed Marshall Washington’s convictions for possession of controlled substances. The court held that the district court did not abuse its discretion by denying discovery of the Wyoming Division of Criminal Investigation’s confidential-informant policy manual, and determined that Washington had access to the confidential-informant agreement before and during trial. The court remanded for correction of clerical omissions in the modified judgment and sentence to comply with the Wyoming Rules of Criminal Procedure.

Holdings

1. The record did not show that Washington was denied access to the signed confidential-informant agreement; he and his counsel had access to and used the agreement before and during trial.
2. The district court did not abuse its discretion by denying discovery of the DCI confidential-informant policy manual because the manual was not material to Washington's defense.
3. The omissions from the modified judgment and sentence were clerical errors that could be corrected on remand rather than grounds for reversal.

Questions Presented

1. Whether the district court abused its discretion by denying discovery of the confidential-informant policy manual.
2. Whether Washington was denied access to the signed confidential-informant agreement before trial.
3. What effect the omission of information required by W.R.Cr.P. 32(b) had on the modified judgment and sentence.

Disposition

affirmed