Elizabeth Dickeson, Appellant (defendant) v. State of Wyoming, Appellee (plaintiff)

Summary

The Wyoming Supreme Court reversed Dickeson's first-degree arson conviction because trial counsel provided ineffective assistance under Strickland by failing to move to suppress her diary and the incriminating statements derived from its warrantless seizure, by failing to object to that evidence at trial, and by cumulatively failing to object to inadmissible evidence and to present an opening statement. Prejudice was shown because, without the diary-derived statements, the only evidence placing Dickeson in Casper on the day of the fire was a brief eyewitness identification. The court reserved the underlying legality of the search and seizure for the district court on retrial and did not reach the sufficiency, suppression, or cumulative-error claims. No separate opinions were filed.