Downing v. State, 2011 WY 113

CI worked with DCI to arrange illegal morphine purchase; buy money of $1,800 given to appellant at JC's house with JC and SM present
CI was wired; recording quality was poor due to background noise
Investigation did not immediately recover buy money or pills due to lack of immediate warrant execution
Pretrial discovery sought information on other CI buys; district court ordered Brady/Hensley material production but limited Rule 16/26.2 discovery
Trial court sustained defense objection to questioning CI about other buys, citing risk of jury distraction
Appellant’s theory: CI sought to con DCI; cross-examination sought to test CI credibility and potential bias

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused discretion interpreting evidence rules	Downing argues exclusion of other buys violated Brady/Hensley and cross-exam rights	Downing asserts cross-exam to test CI credibility is essential to defense	Conviction reversed; new trial remanded

Edwards v. State, 2007 WY 146, 167 P.3d 636 (Wyo.2007) (reversal when evidence central to defense was excluded under 403/404 analogies)
Hensley v. State, 2002 WY 96, 48 P.3d 1099 (Wyo.2002) (impeachment/Brady materiality; material evidence requires reversal)
Dysthe v. State, 2003 WY 20, 63 P.3d 875 (Wyo.2003) (reversed where cross-examination of credibility denied; significant reliance on witness credibility)
Miller v. State, 2006 WY 17, 127 P.3d 793 (Wyo.2006) (limits on cross-examination; confrontation rights may be reasonably restricted)
Hannon v. State, 2004 WY 8, 84 P.3d 320 (Wyo.2004) (confrontation right; testing witness reliability through cross-examination)
Budig v. State, 2010 WY 1, 222 P.3d 148 (Wyo.2010) (limits on cross-examination; harmless-error framework clarified)
Bagley v. Maryland, 473 U.S. 667, 105 S. Ct. 3375 (U.S.1985) (materiality standard for Brady evidence)
United States v. DeSoto, 950 F.2d 626 (10th Cir.1991) (limits on cross-examination; balancing of relevance and prejudicial impact)