Ryan Alexander Brown v. State
2016 WY 107
| Wyo. | 2016Background
- Ryan Brown was convicted of conspiracy to commit first‑degree murder for plotting to kill John Squires; jury returned guilty verdict and Brown received life imprisonment.
- Brown solicited assistance from Eric Farrar and William Ferrill; plans evolved from firearms/suicide ruse to arson of Brown’s house and a pipe‑bomb intended for Squires’ truck.
- Farrar burned Brown’s Arlington house in May 2014 for payment; Brown later paid Farrar $5,000 from insurance proceeds; Farrar also received a $2,500 deposit he later testified about.
- Brown built (and later abandoned) a timed bomb; his daughter and wife discovered the pipe bomb and alerted police; Brown was charged in November 2014.
- At trial the State introduced: (1) a demonstrative video of a pipe‑bomb explosion produced by an officer the weekend before trial, (2) Farrar’s bank statement showing a $2,500 deposit produced four days before trial, and (3) evidence of the prior arson conspiracy between Brown and Farrar.
- Brown appealed claiming due‑process violations from late disclosure of the video and bank statement, and argued improper admission of W.R.E. 404(b) character evidence and absence of a limiting instruction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of pipe‑bomb demonstration video (timely disclosure / relevance) | Brown: video was not timely disclosed and irrelevant; admission violated due process | State: video produced only shortly before trial; not required to disclose what it did not yet possess; defense discovery was late | Court: admission was error because State controlled production and delayed disclosure; error was harmless given overwhelming evidence and thus affirmed conviction |
| Admission of bank statement (timely disclosure) | Brown: statement provided four days before trial; State should have obtained and disclosed it earlier; admission abused discretion | State: Farrar’s payment by Brown was undisputed; statement corroborated testimony and was produced when obtained | Court: admission was erroneous for late disclosure but harmless because it merely corroborated testimony; no reversal |
| Admission of prior arson evidence (W.R.E. 404(b)) | Brown: prior‑bad‑act/arson evidence was improper character evidence and needed limiting instruction | State: arson evidence showed an evolving, single conspiracy and was relevant to motive/plan; alternatively admissible under 404(b) for motive/plan/corroboration | Court: district court reasonably found the arson and murder plans formed one overarching conspiracy, so evidence was substantive and admissible; no limiting instruction required because court did not treat it as 404(b) evidence |
Key Cases Cited
- Ortiz v. State, 326 P.3d 883 (Wyo. 2014) (standard of review for evidentiary rulings and abuse of discretion)
- Marquess v. State, 256 P.3d 506 (Wyo. 2011) (review of admission of evidence for abuse of discretion)
- Armstrong v. Hrabal, 87 P.3d 1226 (Wyo. 2004) (trial court evidentiary rulings entitled to deference)
- Emerson v. State, 988 P.2d 518 (Wyo. 1999) (prosecutor need not disclose evidence it does not possess or control at time, but cannot manufacture delay to avoid disclosure)
- Brazel v. United States, 102 F.3d 1150 (10th Cir. 1996) (evidence within government’s control must be disclosed; prosecutor may not "sandbag" defendant)