Joe Blaz Sanchez, Appellant (defendant Below) v. the State of Wyoming, Appellee (plaintiff Below)

Summary

The Wyoming Supreme Court held that the bifurcated trial procedure under Wyo. Stat. § 7-242.5(a) — which separated the question of whether the defendant committed the 'acts charged' from the remaining elements of the offense and the issue of mental responsibility — violated due process under both the Wyoming Constitution (Art. 1, § 6) and the Fourteenth Amendment, both facially and as applied to Sanchez. The court reasoned that the statute was impermissibly vague as to what evidence was admissible in the first phase, and that in practice the first phase allowed the prosecution to present all evidence of guilt while the defendant was unable to present insanity evidence or fully cross-examine, creating an effectively irrebuttable presumption of intent. The court severed § 7-242.5(a) from the remainder of the statutory scheme, retained the last sentence of that subsection, and reversed and remanded for a new trial. Justice Thomas dissented, arguing that the Wyoming procedure differed materially from the Arizona procedure struck down in State v. Shaw, that juries are presumed to follow instructions, and that the statute could be constitutionally construed — though he agreed the cases should be reversed for a new trial on instruction errors.