Chad Dockter v. State, 396 P.3d 405

Dockter and Yearsley had dated; Yearsley ended the relationship and later told Dockter she was pregnant.
On Aug. 14, 2015, Dockter took an iPhone 6 (given to Yearsley’s daughter); Yearsley declined to press charges then.
On Aug. 15, Dockter entered Yearsley’s apartment unexpectedly while she was showering, grabbed her by the throat, covered her nose and mouth, body-slammed and held her in a bear-hug across bathroom, bedroom, and living room, and punched her thigh before fleeing with her phone after discovering a 911 call.
Yearsley dialed 911 (one call sent) and then used the landline after Dockter left; police arrested Dockter later.
Dockter was charged and convicted of, among other counts, kidnapping (with intent to inflict bodily injury or terrorize) and misdemeanor theft; sentenced to 8–12 years for kidnapping and six months for theft.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence established "confinement" for kidnapping under Wyo. Stat. § 6-2-201(a)	State: brief but forcible restraint inside victim's home, with hands on throat/body across rooms, prevented access to protections and ended only when defendant fled — supports confinement and intent to injure/terrorize	Dockter: conduct was not sufficient to constitute kidnapping; confinement element not met	Affirmed: confinement satisfied; Wyoming statute requires confinement plus specified intent and has no durational requirement, so brief but forcible restraint in home supports kidnapping
Sufficiency of evidence for misdemeanor theft (cell phone)	State: Information was amended to allege taking of iPhone 5 on Aug. 15 during the assault; jurors received corrected written instruction; evidence supports taking on Aug. 15	Dockter: record instruction originally charged Aug. 14 (iPhone 6) and evidence was insufficient for that date/phone	Affirmed: court accepted amendment and found sufficient evidence the iPhone 5 was taken on Aug. 15; conviction supported despite instructional and record irregularities

Barrowes v. State, 390 P.3d 1126 (Wyo. 2017) (standard for reviewing sufficiency of the evidence)
Vaught v. State, 366 P.3d 512 (Wyo. 2016) (discussion of kidnapping definitions and comparison to MPC)
Doud v. State, 845 P.2d 402 (Wyo. 1993) (Wyoming kidnapping statute contains no durational requirement; distinguishes kidnapping from lesser restraint offenses)
Darrow v. State, 824 P.2d 1269 (Wyo. 1992) (confinement may include within-residence isolation analysis)
Keene v. State, 812 P.2d 147 (Wyo. 1991) (kidnapping statutory interpretation precedent)
Dean v. State, 77 P.3d 692 (Wyo. 2003) (false imprisonment as lesser-included offense of kidnapping)