Jess Alcala, Appellant (defendant Below) v. the State of Wyoming, Appellee (plaintiff Below)

Summary

The Wyoming Supreme Court affirmed Jess Alcala's manslaughter conviction for the killing of his wife, holding that circumstantial evidence - the elaborate concealment of her weighted body in a lake, rope matching rope in his possession, his threats, and his numerous untrue statements to police - sufficiently established both the corpus delicti and his connection with the crime. The court upheld the plain-view seizure of a rope and hook at his arrest and the warrantless search of his open boat on a trailer, reasoning that Chimel's limits on searches incident to arrest do not extend beyond the home to a movable boat. It also found no reversible error in the hearsay rulings, the color photographs, the jury instructions (including Allen-type Instructions 23 and 25), the prosecution's leading questions, or the cumulative effect of the alleged errors. Justice Gray, dissenting, would have held the State failed to prove the corpus delicti beyond a reasonable doubt and that the refusal to instruct on corpus delicti required reversal.