Rene Irisrose Daniels v. the State of Wyoming

Summary

The Wyoming Supreme Court affirmed the denial of Rene Irisrose Daniels's W.R.A.P. 21 motion for a new trial, which alleged trial counsel was ineffective for failing to seek suppression of her statements to law enforcement, failing to object to a detective's interview questions about non-existent eyewitnesses, failing to object to a law-enforcement scene video, and in the cumulative effect of those omissions. Applying Strickland, the court assumed without deciding that the challenged evidence could have been excluded and held Daniels showed no reasonable probability of a different verdict, because her admissible initial twenty-five-minute hospital statement, jail telephone calls, surveillance footage, eyewitness testimony, accident reconstruction evidence, and motive evidence independently supported the second-degree murder verdict. Because the motion was denied without an evidentiary hearing, the court reviewed the existing record de novo and resolved the claims on prejudice alone, expressly declining to decide the Miranda, involuntariness, hearsay, or Confrontation Clause questions.