Jessy Michael Dennis v. The State of Wyoming, 302 P.3d 890

Dennis was convicted of aggravated burglary under Wyoming statute § 6-3-301(c)(i) after a jury trial.
The State relied on Dennis’ extrajudicial admissions that he entered the Johnsons’ unlocked home and removed a pistol, which he later returned.
Independent corroborating evidence included the Johnsons’ testimony that no one had permission to enter or remove the pistol and the pistol was found in Mr. Johnson’s truck, with no signs of forced entry.
Dennis did not testify; the district court denied his motion for acquittal based on corpus delicti concerns but allowed trial to proceed.
Dennis proposed a specific-intent jury instruction, which the district court refused as duplicative and potentially confusing; the court gave instructions that tracked the statutory elements and larceny/deprive concepts.
The court ultimately affirmed Dennis’s conviction and rejected his challenges to both corpus delicti sufficiency and jury instructions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Corpus delicti sufficiency	Dennis argues independent corpus delicti proof is lacking without his admissions.	Dennis contends the State failed to prove the crime beyond his admissions.	Sufficient independent corroboration supported the conviction.
Jury instructions on specific intent	Dennis claims the specific-intent instruction was necessary to explain larceny intent beyond general intent.	District court correctly refused duplicative instruction; existing instructions adequately instructed on required intent.	District court did not abuse discretion; instructions as a whole adequately informed the jury.

Craft v. State, 2013 WY 41 (Wy. 2013) (standard of review for sufficiency of evidence; jury could rely on circumstantial evidence)
Mersereau v. State, 2012 WY 125 (Wy. 2012) (corpus delicti requires independent corroboration apart from confession)
Simmers v. State, 943 P.2d 1189 (Wyo. 1997) (corroboration may be circumstantial; corroboration must support essential admitted facts)
Opper v. United States, 348 U.S. 84 (1949) (standard for corroboration of confessions; corroboration must be enough to justify jury inference)
Leppek v. State, 636 P.2d 1117 (Wy. 1981) (evidence of intent may be inferred from acts surrounding the offense)
Walston v. State, 954 P.2d 987 (Wy. 1998) (circumstantial evidence supporting intent to deprive may be inferred from conduct)
Keats v. State, 2003 WY 19 (Wy. 2003) (instructions on appropriate intent; juries should understand the required intent)
Burnett v. State, 2011 WY 169 (Wy. 2011) (adequacy of cumulative jury instructions to inform required elements)