Wyoming Supreme Court
Martin Frias, Appellant (defendant) v. the State of Wyoming, Appellee (plaintiff)
June 26, 19861986 Wyo. LEXIS 578
Summary
The court reversed Frias's second-degree murder conviction and remanded for a new trial. It held that the trial court should have expressly determined whether Frias's interrogation statements were voluntary before admitting them, and that counsel was constitutionally ineffective for failing to investigate substantial evidence supporting a suicide defense. The court did not reach the sufficiency-of-the-evidence claim, and found waiver of the physician-patient privilege and juror-bias claims. Thomas, Chief Justice, dissenting, would have affirmed because the statements were essentially exculpatory, counsel's decisions were strategic, and the alleged new evidence was cumulative.