Sparks v. State, 440 P.3d 1095

In July 2016 Ian Sparks, age 23, hosted two 15‑year‑old girls (DJJ and AK); alcohol was provided and sexual contact occurred; DJJ was intoxicated and reported multiple sexual encounters with Sparks.
State charged Sparks with multiple counts: three second‑degree sexual abuse counts as to DJJ, one third‑degree sexual abuse as to AK, and two counts of furnishing alcohol to minors; after proceedings all sexual counts were bound over and consolidated for trial.
The district court granted the State's motion to join the sexual‑assault charges involving both victims over Sparks' objection, reasoning the offenses were of similar character and part of a connected sequence; the court noted possible Rule 404(b) cross‑admissibility and offered limiting instructions to mitigate prejudice.
Sparks sought to introduce, under the rape‑shield statute, evidence that in 2015 DJJ had made anonymous online statements that she had sex with her father (allegedly false) to impeach her credibility; the court held an in‑chambers hearing and excluded that evidence under W.R.E. 403 and the rape‑shield statute as having limited probative value and high prejudicial/confusing effect.
After a three‑day jury trial Sparks was convicted of one second‑degree sexual‑abuse count (DJJ), one third‑degree count (AK), and both furnishing‑alcohol counts; sentenced to concurrent terms totaling six to ten years; Sparks appealed joinder and exclusion rulings.

Issue	Plaintiff's Argument (Sparks)	Defendant's Argument (State)	Held
Whether joinder of sexual‑abuse charges involving two victims was proper	Joinder was improper because offenses differ in statutory elements, occurred on different dates/locations, and joinder unfairly prejudiced his defense	Offenses are similar (sexual abuse of minors), part of a connected sequence, and evidence would be cross‑admissible; joinder promotes judicial economy	Affirmed: joinder proper under W.R.Cr.P. 8/13; no abuse of discretion and no unfair prejudice given simplicity of facts and jury instructions
Whether exclusion of prior alleged false accusation by DJJ violated evidentiary rules or Sparks' confrontation/right to present a defense	Exclusion prevented impeachment of DJJ's credibility and thus violated Confrontation Clause and right to present a complete defense	Prior internet statements were marginally relevant, highly attenuated by context, would require delving into prior sexual conduct (triggering rape‑shield concerns), and posed unfair prejudice/confusion under Rule 403 and the rape‑shield statute	Affirmed: exclusion was not an abuse of discretion; constitutional claims reviewed for plain error and failed because exclusion did not transgress a clear rule and other impeachment avenues remained available

Hereford v. State, 342 P.3d 1201 (Wyo. 2015) (joinder standard; prefer joint trials absent compelling reasons to sever)
Larkins v. State, 429 P.3d 28 (Wyo. 2018) (joinder upheld where charges involved same victims, witnesses, and general accusations)
Budig v. State, 222 P.3d 148 (Wyo. 2010) (discusses rape‑shield policy and limits on admitting prior sexual/conduct evidence)
Moser v. State, 409 P.3d 1236 (Wyo. 2018) (review of trial court discretion on admissibility and application of rape‑shield balancing)
McGarvey v. State, 325 P.3d 450 (Wyo. 2014) (probative value of prior sexual‑conduct evidence seldom outweighs prejudice under rape‑shield principles)