Miranda Rose Mraz v. The State of Wyoming

Summary

The Wyoming Supreme Court reviewed Miranda Rose Mraz’s conviction for larceny by bailee. The court held that the evidence established only her opportunity to commit the theft and did not sufficiently link her to the stolen property or otherwise corroborate her guilt. The conviction was reversed and the case remanded with instructions to enter a judgment of acquittal.

Holdings

1. Evidence that Mraz had an opportunity to take the money, combined with her failure to initially disclose that she had been in the building earlier, was insufficient to prove beyond a reasonable doubt that she committed the larceny by bailee.
2. There is no standalone category of inadmissible 'alternate suspect' evidence; evidence suggesting that another person committed the crime is admissible if it is relevant, not unfairly prejudicial, non-hearsay, and otherwise satisfies the rules of evidence.

Questions Presented

1. Whether the evidence was sufficient to support Mraz's conviction for larceny by bailee.
2. Whether evidence concerning the possibility that another person entered the Eagles Club and committed the theft was improperly excluded.

Disposition

reversed_and_remanded