Miranda Rose Mraz v. The State of Wyoming, 2014 Wyo. LEXIS 109

Mraz was charged with larceny by bailee in July 2012 for allegedly taking money from a safe at the Eagles Club in Sheridan.
Allegations included alarm-system and surveillance-record evidence showing her entering the building and turning off the alarm at 10:40 a.m. and later entering again; the money was not recovered.
The State moved to preclude alternate-suspect evidence unless a direct nexus to the crime was shown.
Defense presented evidence that others had keys and access to shut off alarms; the alarm was off for periods when others were present, and the safe’s combination was known to others.
The jury found Mraz guilty after four days of trial; the district court sentenced her, suspending the sentence and placing her on probation.
On appeal, the court reversed the conviction on sufficiency-of-the-evidence grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the evidence sufficient to support a guilty verdict?	Mraz	State	No; insufficient evidence to prove guilt beyond a reasonable doubt.
Was alternate-suspect evidence properly excluded?	Mraz	State	Court did not reach independent ruling on this issue due to disposition on sufficiency.
Was the jury instruction improper?	Mraz	State	Instruction challenged as a comment on the evidence; court did not address separately due to sufficiency ruling.

Grady v. State, 197 P.3d 722 (Wy. 2008) (admissibility and relevance of alternate-suspect evidence; requires proper rules of evidence applied)
Bush v. State, 193 P.3d 203 (Wy. 2008) (requires direct nexus; speculative evidence not sufficient)
Wenger v. State, 38 P.2d 339 (Wy. 1934) (opportunity plus motive/possession can support conviction; caution against sole reliance on opportunity)
Newell v. State, 548 P.2d 8 (Wy. 1976) (possession and corroboration required for sufficiency in burglary/larceny context)
Downs v. State, 581 P.2d 610 (Wy. 1978) (opportunity must be accompanied by corroborating links to guilt)