Kramer v. State, 277 P.3d 88

Kramer was convicted of attempted first-degree murder and sentenced to life in prison after a jury trial.
The March 4, 2009 incident began with drinking at a Rawlins bar, followed by an argument and the removal of two men from Kramer's vehicle.
Kramer loaded a gun at home, expressed fear for his mother and sister, and then shot Devore eight times at Devore's residence.
Devore survived the shooting, and trial testimony established the sequence of events leading to the confrontation.
Kramer challenged the jury instructions, claims of ineffective assistance of counsel, and the admissibility of a witness testifying by video conference.
The Wyoming Supreme Court affirmed the conviction on all issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper jury instructions on first-degree murder elements	Inadequate instruction on unanimous finding about defense of others and no venue to decide it	Instructions, taken as a whole, identified issues, burdens, and unanimity; no blending required	No plain error; instructions adequate and unanimous as to issues
Ineffective assistance for investigation and instruction objections	Counsel failed to investigate timing and failed to object to alleged missing elements	Counsel's performance was not deficient; instructions were proper and investigation adequate	No ineffective assistance; defense investigation and advocacy were sufficient
Witness testifying via video conference and confrontation rights	Video testimony denied right to confront the witness in person	Video testimony allowed under public policy and reliability safeguards	Constitutional right preserved; Craig test satisfied; video testimony justified

Six v. State, 180 P.3d 912 (Wyoming 2008) (plain-error review standard for instructional error)
Daves v. State, 249 P.3d 250 (Wyoming 2011) (instructions must correctly state the law and be considered as a whole)
Calene v. State, 846 P.2d 679 (Wyoming 1993) (Calene framework for gauging reasonable investigation)
Peterson v. State, 270 P.3d 648 (Wyoming 2012) (standard for reviewing ineffective-assistance claims post-hearing)
Eaton v. State, 192 P.3d 36 (Wyoming 2008) (de novo review of conclusions of law when trial record developed)
Bowser v. State, 205 P.3d 1018 (Wyoming 2009) (discretion in admitting video-conference testimony)
Bush v. State, 193 P.3d 203 (Wyoming 2008) (video conferencing allowed for health/safety and reliability in Craig framework)
Maryland v. Craig, 497 U.S. 836 (1990) (testimony by alternative means if necessary to protect health while ensuring reliability)
Coy v. Iowa, 487 U.S. 1012 (1988) (face-to-face confrontation preference under confrontation clause)
Ryan v. State, 988 P.2d 46 (Wyoming 1999) (defining confrontation-right standards and trial rights)