Sorensen v. State, 444 P.3d 1283

On Oct. 15, 2017, Melanie Sorensen was arrested at a residence and later strip-searched at the jail; a small baggie was found in the front coin pocket of jeans she was wearing. The Wyoming Crime Laboratory identified the substance as methamphetamine.
At trial the defense conceded presence of the baggie but argued Sorensen did not knowingly possess the methamphetamine, claiming the jeans were not hers and she had only put them on amid household chaos.
The trial judge, after the baggie and lab report were admitted without objection, told jurors they might want gloves to handle the evidence and offered that they could inspect it during deliberations. Defense made no contemporaneous objection.
Forensic fingerprint evidence showed no fingerprints of Sorensen on the baggie; the booking video showed Sorensen wearing the pants and the prosecutor rebutted her testimony that the pants were ill-fitting or not hers.
The jury convicted Sorensen of possession of methamphetamine (third or subsequent offense); she appealed, arguing (1) the judge’s remarks about the baggie were error (per se or plain) and (2) insufficient evidence of knowledge. The Wyoming Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Judicial comment to jury constituted error per se or plain error	Court's wording (referring to the substance as methamphetamine; suggesting glove use) improperly expressed opinion and invaded jury province, requiring reversal	Comments were harmless or not prejudicial because the substance and chain-of-custody were already in evidence; no contemporaneous objection	Plain error standard applies; no structural error; remarks either non-actionable or harmless because lab report was admitted and defendant later testified the baggie was methamphetamine — no reversal
Sufficiency of evidence to prove knowledge	No proof Sorensen knew the baggie or that pants were hers; lack of direct evidence about ownership/fit means knowledge not proven beyond reasonable doubt	Circumstantial evidence (pants fit, booking video, household size, timing, defendant’s conduct and delayed denial) permitted reasonable inference of knowledge	Evidence sufficient: a rational jury could infer Sorensen knew the baggie was in her pocket and its contents; conviction affirmed

Phillips v. State, 597 P.2d 456 (Wyo. 1979) (judicial comments denigrating defendant's testimony can be prejudicial)
Sheeley v. State, 991 P.2d 136 (Wyo. 1999) (expressions of opinion by judge indicating bias infringe jury's role)
Large v. State, 177 P.3d 807 (Wyo. 2008) (distinguishing structural from trial error; prosecutor-elicited guilt opinion treated as trial error)
Granzer v. State, 193 P.3d 266 (Wyo. 2008) (plain error review for unpreserved trial errors such as jury instruction failures)
Ryan v. State, 988 P.2d 46 (Wyo. 1999) (judge must not express opinion on evidence; curative instruction can alleviate prejudice)
Snow v. State, 216 P.3d 505 (Wyo. 2009) (judge's improper evidentiary guidance to jury during deliberations can require reversal)
Mersereau v. State, 286 P.3d 97 (Wyo. 2012) (judicial explanation of evidentiary limits that intrudes on jury role can be prejudicial)
Weaver v. Massachusetts, 137 S. Ct. 1899 (U.S. 2017) (distinction between structural and trial errors; harmless-error framework)