Jeremiah D. Leach v. The State of Wyoming, 2013 WY 139

Leach was convicted by a Uinta County jury of first degree sexual assault against a physically helpless woman, LT.
Leach challenged admission of statements he made to police, arguing they were inadmissible hearsay or improperly admitted under Rule 804(b)(3).
LT testified about a night of drinking, LT’s rape in Leach’s home, and LT’s injuries; LT’s blood-spotted toilet paper and hospital evidence were collected.
Detective interrogation of Leach was recorded; Leach initially denied, then admitted knowing LT but claimed it wasn’t forcible; a later DNA cheek swab was collected.
The State introduced recordings and transcripts of Leach’s statements over objections; the court overruled objections and admitted the statements for the jury.
At trial, witnesses testified about the house dynamics and custody issues; the State argued the house owner’s motive to deny the assault could be biased; the court sustained some objections, others were not struck.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of Leach’s statements to police	Leach	Leach	Admission proper; statements are party-opponent admissions not hearsay
Prosecutor's rebuttal closing referring to facts not in evidence	Leach	Leach	No reversible error; arguments within permissible inference

Marquess v. State, 256 P.3d 506 (Wy. 2011) (abuse-of-discretion standard for admitting evidence)
Bromley v. State, 219 P.3d 110 (Wyo. 2009) (persuasiveness of federal-evidence analogies)
Belden v. State, 73 P.3d 1041 (Wyo. 2003) (prosecutor may reflect on evidence in closing)
Grady v. State, 197 P.3d 722 (Wyo. 2008) (plain-error review framework)
United States v. Mitchell, 613 F.2d 779 (10th Cir. 1980) (motion to strike and preserve errors; evidentiary considerations)