Kyle Jordan Lawrence v. State, 354 P.3d 77

Appellant Kyle Lawrence was convicted of voluntary manslaughter after self-defense claim; district court excluded victim’s methamphetamine intoxication evidence via motion in limine.
Victim Andrew Klakken died from gunshot wounds; autopsy toxicology showed methamphetamine present.
State charged first-degree murder, aggravated assault and possession of a deadly weapon; latter two charges were dismissed.
District court found meth intoxication evidence irrelevant under W.R.E. 401 absent knowledge of victim’s intoxication by Appellant; and it was also excluded under W.R.E. 403 for prejudice.
Trial proceeded on self-defense theory; jury convicted of voluntary manslaughter and sentencing was 14 to 20 years.
Appellant sought post-trial relief and limited remand for ineffective assistance claim; district court and appellate ruling focused only on evidentiary issue and not ineffective assistance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the district court's ruling on the meth evidence an abuse of discretion?	Lawrence	Klakken	Yes, no abuse of discretion

Brock v. State, 272 P.3d 933 (Wyo. 2012) (review of evidentiary rulings for abuse of discretion)
Edwards v. State, 167 P.3d 636 (Wyo. 2007) (standard for abuse of discretion in evidentiary rulings)
McDermott v. State, 962 P.2d 136 (Wyo. 1998) (probative value and prejudice balancing)
Bromley v. State, 219 P.3d 110 (Wyo. 2009) (admissibility of methamphetamine evidence depends on knowledge of victim’s intoxication and state of mind)
Plew, 745 P.2d 102 (Ariz. 1987) (victim’s intoxication admissible where defendant knew of intoxication and it bears on self-defense)
Sipe v. State, 404 S.W.3d 164 (Ark. App. 2012) (victim’s intoxication relevance depends on defendant’s knowledge of intoxication)