Narrative Opinion Summary
This case involves the appeal of a defendant, convicted of aggravated vehicular homicide and two DUI misdemeanors, challenging the trial court's exclusion of expert testimony, its jury instructions, and the legality of the imposed sentences. The Supreme Court of Wyoming addressed the exclusion of expert testimony on EMDR therapy, determining that the trial court abused its discretion under Daubert standards by not allowing the expert to testify, thereby infringing on the defendant's right to present a complete defense. The court ordered a new trial for the aggravated vehicular homicide conviction. Additionally, the court found error in the trial court's handling of the DUI charges, asserting that only one conviction should stand as the charges were alternative counts from the same act, thus reversing the DUI convictions. The court upheld the jury instruction regarding the irrelevance of seat belt usage in determining proximate cause, aligning this with established legal precedents. The outcome necessitates a retrial for the vehicular homicide charge while directing the trial court to enter a judgment for a single DUI violation, highlighting the appellate court's emphasis on procedural and substantive fairness in the trial process.
Legal Issues Addressed
Exclusion of Expert Testimony under Daubert Standardssubscribe to see similar legal issues
Application: The district court's exclusion of expert testimony on EMDR therapy was reversed as it was found to be an abuse of discretion, failing to meet Daubert's reliability and relevance requirements.
Reasoning: The district court concluded that this testimony did not satisfy Daubert's reliability criteria, was determined to be erroneous, as her practical experience and the recognized efficacy of EMDR were clearly established.
Jury Instructions on Proximate Causesubscribe to see similar legal issues
Application: The court upheld the district court's decision to instruct the jury that seat belt usage was not relevant to determining proximate cause in the vehicular homicide charge.
Reasoning: Ms. Stalcup argues that the district court erred by responding 'No' to the jury's inquiry regarding the consideration of seat belt usage by her and Mr. Lorenz during the crash.
Right to Present a Complete Defensesubscribe to see similar legal issues
Application: The exclusion of Ms. Schaad's expert testimony on EMDR therapy was found to infringe upon Ms. Stalcup's constitutional right to present a defense, necessitating a new trial.
Reasoning: The Constitution guarantees criminal defendants a meaningful opportunity to present a complete defense, which includes the right to introduce competent and reliable evidence central to their case.
Sentencing for Multiple DUI Convictionssubscribe to see similar legal issues
Application: The court reversed the district court's imposition of sentences for two DUI counts, determining only one conviction and sentence should be entered under the relevant statute.
Reasoning: Regarding sentencing, Ms. Stalcup contends that the district court issued an illegal sentence by imposing two six-month terms of incarceration for two DUI counts, arguing that only one conviction should have been entered under Wyo. Stat. Ann. 31-5-233.