Facts
- Donald Murray and the victim were friends and co-workers on an oil rig near Granger, Wyoming.
- After finishing work on September 30, 1991, they began drinking. They later argued at a bar in Mountain View, Wyoming, about a co-worker.
- Murray left the bar before the argument became physical, went to another bar, continued drinking, and drove home.
- Around 11:00 p.m., the victim’s cousin drove the victim to Murray’s home so the victim could retrieve work clothes from the back of Murray’s truck.
- As the cousin drove down Murray’s driveway, she saw muzzle flashes and heard gunshots. Murray was on the porch holding a handgun.
- The victim got out, identified himself, and said he only wanted his clothes. Murray yelled for him to get off the property and fired additional shots, including shots that struck near the victim’s feet.
- Murray approached until he was within a few feet of the victim. As the victim turned back toward the vehicle, Murray fired several more shots.
- The area contained many rocks. One bullet ricocheted off a rock, severed the victim’s femoral artery and femoral vein. The victim also suffered a gunshot wound to the buttocks.
- The victim was driven to a nearby bar, then transported by ambulance, but died later that night from blood loss.
- Evidence at trial showed Murray had significant experience with firearms.
- A magistrate issued an arrest warrant supported by probable cause. When officers arrested Murray, they did not promptly tell him the charge or that a warrant had issued, as required by W.R.Cr.P. 4(c)(3).
- After Miranda warnings, Murray gave a statement. During the interview, officers later told him the victim had died and that he was being charged with second-degree murder.
- Murray was tried and convicted by a jury of involuntary manslaughter (recklessly causing the death of another). The court imposed restitution and other payments, including a $10,000 payment to the Wyoming Crime Victims’ Compensation Fund.
Issues
- Whether officers’ intentional failure to inform Murray of the reason for arrest and existence of a warrant, in violation of W.R.Cr.P. 4(c)(3), invalidated the arrest and required suppression of his statements.
- Whether the evidence was sufficient to support a conviction for involuntary manslaughter (reckless killing), rather than only criminally negligent homicide.
- Whether the sentencing court erred by ordering restitution and assessing a $10,000 payment to the Wyoming Crime Victims’ Compensation Fund without determining Murray’s ability to pay.
Decision
- The Wyoming Supreme Court affirmed the conviction and the denial of the motion to suppress.
- The court held that the W.R.Cr.P. 4(c)(3) violation was a violation of a procedural rule and did not, by itself, invalidate an arrest executed under a valid warrant or require suppression absent a constitutional violation.
- The court held the evidence was sufficient for a rational jury to find Murray acted recklessly and therefore to convict him of involuntary manslaughter.
- The court affirmed the financial portions of the sentence in part but modified the judgment by setting aside the $10,000 payment to the Crime Victims’ Compensation Fund because the record lacked a supporting ability-to-pay finding for that payment.
Legal Principles
- A failure to comply with a rule requiring an officer to inform an arrestee of the charge and the existence of a warrant is a procedural violation; it does not automatically make a warrant arrest unlawful.
- Suppression is generally reserved for constitutional violations; courts do not automatically apply the exclusionary rule to nonconstitutional violations of court rules.
- Involuntary manslaughter based on recklessness requires proof that the defendant was aware of, and consciously disregarded, a substantial and unjustifiable risk; criminal negligence involves failing to perceive that risk.
- On sufficiency review, the evidence and reasonable inferences are viewed in the light most favorable to the State, and conflicting evidence is disregarded.
- Sentencing orders imposing significant payments must be supported by findings and record support on ability to pay when required; where such support is missing for a specific assessment, that portion of the sentence may be set aside while the remainder is affirmed.
Conclusion
The Wyoming Supreme Court affirmed Murray’s involuntary manslaughter conviction, ruling that officers’ noncompliance with W.R.Cr.P. 4(c)(3) did not require suppression because the arrest rested on a valid warrant and no constitutional violation was shown; it also held that Murray’s multiple shots toward the victim in a rocky area, combined with Murray’s firearms experience, permitted a jury finding of recklessness, and it modified the sentence only by setting aside the unsupported $10,000 Crime Victims’ Compensation Fund payment.