Richard John Jahnke, Appellant (defendant) v. the State of Wyoming, Appellee (plaintiff)

Summary

The Wyoming Supreme Court affirmed Richard Jahnke's conviction of voluntary manslaughter and his sentence of five to fifteen years for the shotgun killing of his abusive father. The court held the trial judge acted within his discretion in limiting voir dire questions about the father's abusive discipline and jurors' views on the justification for taking human life, and in excluding proffered expert testimony from a forensic psychiatrist about the 'battered-child syndrome,' because no evidence of an actual or threatened imminent assault supported a self-defense context at the time of the ruling. The sentence, being within statutory limits, presented no abuse of discretion. Justice Brown specially concurred, while Justices Rose and Cardine dissented, contending that voir dire was improperly restricted and that expert psychiatric testimony explaining how battered persons perceive danger was necessary and should have been admitted.