## Facts

- Richard John Jahnke, age 16, shot and killed his father outside the family home in Cheyenne, Wyoming, on November 16, 1982.
- Jahnke used a shotgun and inflicted the fatal wounds; identity and causation were not disputed.
- The defense asserted a history of severe physical and psychological abuse by the father toward the children.
- After an altercation and alleged threats by the father, Jahnke armed himself, waited for his father to return, and shot him as the father got out of a car.
- Jahnke was charged with first-degree murder and conspiracy to commit first-degree murder; the jury convicted him of the lesser-included offense of voluntary manslaughter.
- The district court sentenced Jahnke to imprisonment for 5 to 15 years.

## Issues

1. Whether the trial court abused its discretion by limiting voir dire questions about jurors’ attitudes toward parental abuse and whether killing is ever justified.
2. Whether the trial court erred by excluding a forensic psychiatrist’s testimony recounting Jahnke’s statements and offering opinions supporting self-defense based on a “battered child” theory.
3. Whether sentencing a 16-year-old to 5 to 15 years for voluntary manslaughter was an abuse of discretion.

## Decision

- The Wyoming Supreme Court affirmed the conviction, judgment, and sentence.
- The court held the voir dire limitations were within the trial court’s discretion because voir dire is to identify bias, not to precondition jurors to the defense theory.
- The court upheld exclusion of the psychiatrist’s proposed testimony insofar as it would introduce Jahnke’s out-of-court statements and otherwise did not materially assist a legally valid self-defense claim.
- The court held the sentence was within statutory limits and imposed after consideration of relevant information; no abuse of discretion was shown.

## Legal Principles

- Trial courts have broad discretion to control voir dire; limiting case-specific or argumentative questioning is permissible when general inquiries into impartiality are allowed.
- Self-defense requires an actual or reasonably apparent imminent threat; a history of abuse does not create a distinct justification to use deadly force absent imminence at the time of the killing.
- Expert witnesses may rely on inadmissible information to form opinions, but courts may prevent experts from presenting a party’s out-of-court statements to the jury as substantive evidence.
- Expert testimony must be relevant to a fact of consequence under the governing legal standard; if the factual setting does not support an imminent-threat theory, psychological-syndrome evidence tied to self-defense may be excluded.
- A sentence within statutory bounds is reviewed for abuse of discretion and will be upheld absent an erroneous basis or improper considerations.

## Conclusion

The court affirmed Jahnke’s voluntary manslaughter conviction and 5–15 year sentence, holding that restricting voir dire to avoid case-preconditioning, excluding battered-child psychiatric evidence for lack of admissible content and legal relevance to imminence, and imposing a statutorily authorized sentence were all within the trial court’s discretion.


Jahnke v. State, 682 P.2d 991 (Wyo. 1984)