Robert Reginald Springfield, Appellant (defendant) v. State of Wyoming, Appellee (plaintiff)

Summary

The Wyoming Supreme Court affirmed Robert Springfield's conviction for first-degree sexual assault, holding that the trial court did not abuse its discretion in admitting FBI DNA profiling evidence and the accompanying population statistics under Wyo.R.Evid. 702. The court held that questions about FBI laboratory protocol compliance and population substructure (including the absence of Crow tribal members from the database) go to the weight of the evidence for the jury rather than admissibility, and that a declared DNA match is 'virtually meaningless' without statistical probability evidence. The court also found sufficient evidence of identity, no plain error in the camera-theft evidence, no speedy trial violation after excluding continuance time, and no cumulative error. Justice Thomas concurred specially, agreeing the conviction should be affirmed but urging reaffirmance of Rivera's rule that prosecutors should not introduce DNA statistical probability evidence because it effectively amounts to an opinion on guilt and undermines the right to a jury trial.