## Facts

- Ann Helton was charged with first-degree murder for shooting and killing her husband in their Casper, Wyoming home.
- The shooting occurred around 6:00 a.m. on October 15, 1952, in the kitchen of the Helton residence.
- Helton used a .38-caliber Smith & Wesson revolver and fired five shots.
- Three shots struck the victim: one grazed his neck under the chin, one passed through his body, and one passed through his head.
- No living eyewitnesses existed other than Helton; the State relied on physical evidence, photographs, and Helton’s own prior statements, including sworn testimony she gave at a coroner’s inquest before her arrest.
- At about 7:10 a.m., law enforcement responded to an emergency call and found the victim lying on his back on the kitchen floor; the revolver was beside the body.
- A responding officer observed what appeared to be powder burns on the victim’s underwear over the abdomen, suggesting close-range firing.
- The prosecution introduced photographs of the scene, the transcript of Helton’s inquest testimony, and extensive witness and exhibit evidence.
- Helton’s defense theory was self-defense, grounded in her account of the deceased’s conduct, prior mistreatment, and threats, and her claim that she reasonably believed deadly force was necessary.
- A jury found Helton guilty of second-degree murder, and the district court sentenced her to a minimum term of 20 years and a maximum term of 25 years in the state penitentiary.
- Helton appealed, challenging (among other things) admission of her inquest testimony and the correctness and completeness of jury instructions on self-defense.

## Issues

1. Whether Helton’s sworn testimony at the coroner’s inquest was properly admitted against her at trial.
2. Whether the trial court’s instructions on self-defense—including consideration of prior threats and the right to act on apparent danger—correctly stated the law when read as a whole.
3. Whether the evidence was sufficient to sustain the second-degree murder conviction in light of Helton’s self-defense claim and the largely circumstantial nature of the proof.

## Decision

- The Wyoming Supreme Court affirmed the judgment and sentence.
- The court held that Helton’s coroner’s inquest testimony was admissible as her voluntary statements and could be used by the State at trial.
- The court concluded the self-defense instructions, taken together, fairly and correctly submitted the law to the jury, including the rule permitting action based on reasonable appearances of danger and consideration of the deceased’s prior threats and conduct.
- The court held the evidence was sufficient for the jury to reject self-defense and find second-degree murder, and it declined to reweigh credibility or conflicts in the evidence on appeal.

## Legal Principles

- A defendant’s voluntary sworn statements at a coroner’s inquest may be received in evidence against the defendant in a later criminal trial as admissions, so long as the statements were not compelled in violation of constitutional rights.
- Self-defense may be justified based on reasonable appearances of imminent danger of death or serious bodily harm; the jury may consider the defendant’s knowledge of the deceased’s prior threats and prior conduct in deciding the reasonableness of the defendant’s belief.
- Jury instructions are evaluated as a whole; a challenged portion will not warrant reversal if the overall charge correctly states the law and fairly presents the defendant’s theory.
- On review of sufficiency of the evidence, the appellate court gives substantial deference to the jury’s resolution of credibility questions and factual disputes and will not substitute its judgment where the record supports the verdict.
- Circumstantial and physical evidence, combined with a defendant’s statements, can be sufficient to support a homicide conviction even in the absence of eyewitness testimony.

## Conclusion

The Wyoming Supreme Court affirmed Ann Helton’s second-degree murder conviction and 20–25 year sentence, ruling that her coroner’s inquest testimony was properly admitted, the jury was adequately instructed on self-defense (including apparent danger and prior threats), and the record contained sufficient evidence for the jury to reject self-defense and return a verdict of second-degree murder.


State v. Helton, 276 P.2d 434 (1954)