Young v. State, 418 P.3d 224

Eight-year-old FH reported sexual abuse by Darrell Wayne Young occurring two years earlier; State charged him with two counts of first-degree and three counts of second-degree sexual abuse of a minor.
Young had a prior similar conviction; he faced enhanced penalties to life without parole upon conviction.
Defense requested a pretrial competency hearing; at the hearing FH initially said she did not remember the abuse but later demonstrated recollection of the relevant time period and related events.
The district court applied Wyoming’s child-witness competency framework (Larsen factors) and found FH competent to testify; FH then testified at trial and the jury convicted Young on all counts.
Young appealed solely arguing the court erred in finding FH competent (focusing on the Larsen third factor: memory). The Wyoming Supreme Court reviewed for abuse of discretion and affirmed.

Issue	Plaintiff's Argument (Young)	Defendant's Argument (State)	Held
Whether the district court erred in finding FH competent to testify	FH told the judge she could not remember the abuse; therefore she lacked a sufficient memory to testify (fails Larsen factor 3)	Competence focuses on mental capacity, not perfect recollection; FH’s full testimony showed she understood the topic, could remember the time period, and was merely reluctant to discuss details	Court affirmed: no abuse of discretion — FH was competent under Larsen

Larsen v. State, 686 P.2d 583 (Wyo. 1984) (adopted five-part test for child witness competency)
Gruwell v. State, 254 P.3d 223 (Wyo. 2011) (competency focuses on mental abilities; trial judge’s observations entitled to deference)
Griggs v. State, 367 P.3d 1108 (Wyo. 2016) (district court competency findings not disturbed absent clear error)
Mersereau v. State, 286 P.3d 97 (Wyo. 2012) (competence requires understanding oath and ability to receive, remember, and narrate)
English v. State, 982 P.2d 139 (Wyo. 1999) (discussing standard of review and deference to trial court)