Charles A. Santistevan v. The State of Wyoming
Annotate this CaseThe Supreme Court of Wyoming upheld the conviction of Charles Anthony "Tony" Santistevan for multiple counts of sexual assault and one count of voyeurism. The court found that the district court did not abuse its discretion when it allowed the state to introduce evidence that Santistevan's sexual relationship with the victim, R.S., began when she was a minor. This evidence was introduced under the Wyoming Rules of Evidence (W.R.E.) 404(b), which allows evidence of other crimes, wrongs, or acts for certain purposes, such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident. Santistevan argued that the introduction of this evidence was an abuse of the district court's discretion, but the Supreme Court disagreed. It held that the evidence was relevant and admissible under W.R.E. 404(b) to show an ongoing scheme or plan and to demonstrate Santistevan's course of conduct, and to provide a complete story to the jury about the relationship between Santistevan and R.S., thereby aiding in determining the issue of consent in the sexual assault charges.
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