Kyle Jordan Lawrence v. State

Summary

The Supreme Court of Wyoming affirmed Kyle Jordan Lawrence’s conviction for voluntary manslaughter. The court held that evidence of the shooting victim’s methamphetamine intoxication was not relevant to Lawrence’s self-defense claim because there was no evidence Lawrence knew the victim was intoxicated, and it therefore found no abuse of discretion in excluding the evidence.

Holdings

1. Evidence of the victim's methamphetamine intoxication was not relevant to Lawrence's self-defense claim because Lawrence presented no evidence that he was aware of the victim's intoxication when he used deadly force.
2. The district court did not abuse its discretion in excluding evidence of Klakken's methamphetamine intoxication.

Questions Presented

1. Whether the district court abused its discretion by excluding evidence of the victim's methamphetamine intoxication under Wyoming Rules of Evidence 401 and 403.
2. Whether exclusion of the evidence deprived Lawrence of his constitutional right to present a defense.

Disposition

affirmed