Willoughby v. State, 253 P.3d 157

Victim Elizabeth Ehlers was murdered in Sublette County, WY in 1984; Willoughby was convicted of first‑degree murder in 2010 based largely on eye‑witness and forensic testimony and a theory of alibi.
Trial involved multiple discovery and witness-credibility issues arising from undisclosed statements, late autopsy testimony, and reconstructive sketches; district court admitted some disputed evidence under curative instructions.
Defense theories centered on alibi and challenged forged drilling log; prosecution presented evidence including anonymous Crime Stoppers tip and interviews suggesting inconsistent witness statements.
The post‑trial motion for new trial raised several claims of prosecutorial misconduct and discovery violations, including nondisclosure of a threat by Willoughby to a witness, and destruction or non-retention of sketches.
The district court denied the new trial motion without a hearing on several issues; the Wyoming Supreme Court affirms, finding no reversible error or prejudice requiring reversal.
Resolution: Court affirms conviction and denial of new trial motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion denying a new trial.	Willoughby shows prejudice from undisclosed threats and discovery failures.	Appellant argues missteps tainted trial fairness.	No abuse; denial affirmed.
Did prosecutors violate discovery orders by undisclosed witness statements and 404(b) evidence?	Discovery gaps prejudiced defense.	Any breach was not prejudicial.	No reversible prejudice; affirm.
Did 404(b) uncharged misconduct evidence and pre‑trial rulings affect fairness?	State improperly introduced prior acts without clear orders.	Court properly managed disclosures; no prejudice.	Not reversible; affirm.
Was there a Brady/undisclosed R.H. audiotape issue requiring new trial?	Late disclosure of audiotape violated Brady safeguards.	No material new information; cross‑examination available.	No error requiring reversal; affirm.
Did the prosecution commit misconduct by eliciting testimony that a witness lied?	Officer improperly vouched about credibility.	Context shows interrogation of credibility already before jury.	No plain error; affirm.

Yellowbear v. State, 2008 WY 4 (Wyo. 2008) (new-trial standard and prejudice; mistrial as drastic remedy)
Best v. State, 769 P.2d 385 (Wyo. 1989) (hearing not required if record suffices for decision)
Janpol v. State, 178 P.3d 396 (Wyo. 2008) (jurors presumed to follow curative instructions)
Ceja v. State, 2009 WY 71 (Wyo. 2009) (Rule on discovery and disclosure; context of Rule 16)
Trombetta v. Illinois, 467 U.S. 479 (U.S. 1984) (due process: apparent exculpatory value and preservation)
Arizona v. Youngblood, 488 U.S. 51 (U.S. 1988) (bad faith destruction required if exculpatory value indeterminate)
Hollenbach v. State, N/A (-) (recognizes limits on witness-credibility testimony by officers (contextual to rule))