Gabriel R. Drennen, Appellant (defendant) v. the State of Wyoming, Appellee (plaintiff)

Summary

The court reversed the convictions for first-degree murder and aggravated assault and battery because prosecutors repeatedly misstated Wyoming self-defense law by telling the jury that shooting an unarmed person was unlawful, and the misconduct prejudiced the defense under plain-error review. The court also clarified that self-defense instructions must distinguish between an initial aggressor's duty to withdraw and the general requirement to consider reasonable alternatives before using deadly force, and it identified additional defects in the aggravated-assault and homicide instructions. The ineffective-assistance claim was not decided in detail because the case was being remanded for a new trial.