Jackson v. State
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The Supreme Court affirmed Defendant's conviction of strangulation of a household member, holding that there was no error in the district court's evidentiary rulings.
On appeal, Defendant argued, among other things, that the district court abused its discretion by admitting recorded phone calls into evidence. As to this evidence, the district court made only a cursory Wyo. R. Evid. 404(b) ruling and did not review any of the Gleason factors. The Supreme Court affirmed, holding (1) Defendant was not prejudiced by the district court's decision to admit evidence that Defendant violated a no-contact order when he called the victim from jail; and (2) the district court did not err when it admitted the victim's hearsay statement recorded on the responding officer's body cam as an excited utterance.
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