Deborah Ann Jahnke, Appellant (defendant) v. the State of Wyoming, Appellee (plaintiff)

Summary

The Wyoming Supreme Court affirmed Deborah Jahnke's conviction of aiding and abetting voluntary manslaughter and her sentence of three to eight years. The court held that voluntary manslaughter is a lesser-included offense of first and second degree murder under Wyoming law because the 'sudden heat of passion' language describes the absence of malice rather than a separate element; that her statement to sheriff's officers was admissible because she knowingly, voluntarily and intelligently waived her rights under the totality of the circumstances; that the statute vesting discretion in prosecutors to charge juveniles as adults is constitutional; and that her sentence was within statutory limits and involved no abuse of discretion. Chief Justice Rooney and Justice Brown filed concurrences; Justice Cardine, joined by Justice Rose, dissented, arguing the statement should have been suppressed and the conviction reversed.