Leyva v. State
2007 Wyo. LEXIS 146, 165 P.3d 446, 2007 WY 136 (2007)
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Rule of Law:
Evidence of uncharged misconduct that is inextricably intertwined with the charged offense may be admissible under W.R.E. 404(b) if it serves a proper purpose, such as providing the 'complete story' or 'course of conduct' necessary for the natural development of the facts, and its probative value is not substantially outweighed by the danger of unfair prejudice.
Facts:
- On September 8, 2005, Kelly King reported that a television set had been stolen from his apartment.
- Police arriving at the apartment complex observed the television in the front seat of a vehicle owned by Erin Setright.
- Officers saw Setright and Mr. Leyva get into the vehicle; Setright told the officers that Leyva had the television with him when he asked her for a ride.
- Police detained Leyva and, upon discovering an outstanding warrant, arrested him.
- A search of Leyva revealed a knife, a bag with methamphetamine residue, and a brass pipe with marijuana residue.
- Leyva claimed he had borrowed the television and the pants he was wearing from King.
- Leyva gave inconsistent explanations for the items in his pockets, stating the pipe must have been in the pants when he borrowed them that morning, but that he had placed his own knife in the pocket the night before.
Procedural Posture:
- Mr. Leyva was charged in Wyoming district court (trial court) with one felony count of burglary and one felony count of possession of a controlled substance, third offense.
- Leyva entered into a plea agreement, pleading guilty to the possession charge in exchange for the State dismissing the burglary charge.
- At a sentencing hearing, Leyva expressed confusion over the terms of his sentence and, at his own request, the district court permitted him to withdraw his guilty plea.
- The case proceeded to a jury trial on both original counts.
- During trial, the court admitted evidence that Leyva possessed a marijuana pipe, over his objection that it was improper uncharged misconduct evidence.
- The jury found Mr. Leyva guilty on both charges.
- Mr. Leyva (appellant) appealed his convictions to the Supreme Court of Wyoming, arguing the trial court erred in admitting the evidence. The State is the appellee.
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Issue:
Did the district court err by admitting evidence of uncharged misconduct—specifically, possession of a marijuana pipe—during a trial for burglary and methamphetamine possession, where that evidence was part of the defendant's inconsistent post-arrest statements?
Opinions:
Majority - Burke, J.
No. The district court did not err in admitting the evidence of uncharged misconduct because it was properly analyzed and admitted for a valid purpose under W.R.E. 404(b). The evidence regarding the marijuana pipe was not offered to prove Leyva's character or propensity to commit drug crimes, but for the proper purpose of providing the 'complete story' to the jury. It was inextricably intertwined with Leyva's inconsistent statements to police, which were relevant to his credibility and the veracity of his claim that he had borrowed the stolen television. The district court correctly, albeit after some initial hesitation, conducted the required four-part analysis and concluded that the evidence's probative value in explaining Leyva's contradictory statements outweighed its potential for unfair prejudice.
Analysis:
This decision reaffirms the 'complete story' or 'intrinsic evidence' doctrine as a proper purpose for admitting evidence under Rule 404(b). Critically, the court clarifies that labeling evidence as 'intrinsic' or 'part and parcel' of the charged crime does not exempt it from a full 404(b) analysis. This holding serves as a procedural safeguard, requiring trial courts to explicitly weigh the purpose, relevance, and prejudicial effect of such evidence on the record, rather than admitting it automatically under a broad narrative-completion theory. The case thus reinforces the gatekeeping function of the trial court in policing the use of uncharged misconduct evidence to ensure a defendant is convicted based on the crime charged, not on general bad character.
