BRUYETTE v. Wyoming
253 P.3d 512
Wyo.2011Background
- Bruyette charged with felony possession of marijuana under Wyo. Stat. § 35-7-1031(c)(iii).
- He claimed California medical marijuana prescription card supported by a physician's advice.
- State moved in limine to bar any medical marijuana defense or evidence; district court granted.
- Bruyette testified and referenced a medical marijuana card; court struck that testimony and admonished as not a defense.
- District court refused defense jury instruction; Bruyette convicted and sentenced; appeal asserted denial of right to present a defense.
- Wyoming Supreme CourtAffirmed the trial court’s exclusion of medical marijuana evidence; held no defense existed under Wyoming law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to present a defense guaranteed by constitutions. | Bruyette argues denial of the defense. | State contends no valid defense existed in Wyoming law. | Affirmed; not a violation; California card irrelevant under Wyoming law. |
Key Cases Cited
- Burns v. State, 246 P.3d 283 (Wyo. 2011) (possession illegal even with foreign medical prescription)
- Proffit v. State, 191 P.3d 974 (Wyo. 2008) (right to present evidence limited by relevance)
- Dysthe v. State, 63 P.3d 875 (Wyo. 2003) (limits on admissibility of evidence in defense)
- Crane v. Kentucky, 476 U.S. 683 (1986) (due process & meaningful opportunity to present a defense)