353 P.3d 693
Wyo.2015Background
- Matthew Snyder was charged with five counts of first-degree sexual abuse of a minor based on repeated sexual assaults of JL in 2012; JL became pregnant and later bore a child.
- State sought to introduce uncharged-misconduct evidence under W.R.E. 404(b) that Snyder had sexually abused JL previously in California; DNA testing was offered to corroborate that prior abuse.
- At a pretrial Gleason hearing the court admitted the 404(b) evidence, including DNA results, as necessary to tell the story and to show motive, intent, and course of conduct.
- At trial the State’s DNA expert testified to the lab’s probability of paternity (99.99999998638%) and referenced the Wyoming statutory paternity presumption (combined paternity index ≥100), noting Snyder’s index was ~7.3 billion to 1. No objection was made.
- Snyder was convicted on all counts and appealed, arguing plain error and due process violations from admission of testimony about a civil statutory presumption of paternity that does not apply in criminal cases.
Issues
| Issue | Snyder's Argument | State's Argument | Held |
|---|---|---|---|
| Whether admission of testimony referencing the Wyoming civil paternity presumption constituted plain error or violated due process | Testimony invoked a civil statutory presumption that improperly shifted burden to Snyder and exaggerated DNA significance; Rule 303 (presumptions in criminal cases) was not followed | The testimony was offered only to explain lab methods and to support admissible 404(b) evidence; any error did not prejudice Snyder under plain-error standard | No plain error; testimony was contextual and DNA probability plus other evidence overwhelmingly supported paternity and guilt, so no due process violation |
Key Cases Cited
- Faubion v. State, 233 P.3d 926 (Wyo. 2010) (plain-error standard articulated)
- Gleason v. State, 57 P.3d 332 (Wyo. 2002) (admission of similar sexual misconduct evidence in child sexual-abuse cases)
- Hernandez v. State, 162 P.3d 472 (Wyo. 2007) (discussing Yates test for assessing impact of mandatory presumptions)
- Yates v. Evatt, 500 U.S. 391 (U.S. 1991) (two-part test for evaluating jury instructions with mandatory presumptions)
- Hereford v. State, 342 P.3d 1201 (Wyo. 2015) (Rule 303 requires submission and specific jury instruction when presumed facts are presented to jury)