Snyder v. State

• Citation: 496 P.3d 1239
• Decision Date: 12 October 2021
• Docket Number: S-20-0245
• Parties: Jamie Stuart SNYDER, Appellant (Defendant), v. The STATE of Wyoming, Appellee (Plaintiff).
• Court: Wyoming Supreme Court

496 P.3d 1239

Jamie Stuart SNYDER, Appellant (Defendant),

v.The STATE of Wyoming, Appellee (Plaintiff).

S-20-0245

Supreme Court of Wyoming.

October 12, 2021

Representing Appellant: Office of the State Public Defender: Diane Lozano, State Public Defender; Kirk A. Morgan, Chief Appellate Counsel; Lauren McLane, Faculty Director, Matthew Klein, Student Director, Nathan Yanchek, Student Attorney, Thomas C. Fogle, Student Attorney, of the University of Wyoming Law Defender Aid Clinic. Argument by Mr. Klein.

Representing Appellee: Bridget Hill, Wyoming Attorney General; Jenny L. Craig, Deputy Attorney General; Joshua C. Eames, Senior Assistant Attorney General. Argument by Mr. Eames.

Before FOX, C.J., and DAVIS^* , KAUTZ, and GRAY, JJ., and FROELICHER, D.J.

FROELICHER, District Judge.

[¶1] Jamie S. Snyder appeals from his conviction for the first-degree murder of Wade Erschabek following a jury trial. Mr. Snyder raises three issues on appeal. First, Mr. Snyder challenges a circuit court decision that he was competent and fit to proceed. Second, he contends the district court erred in deciding that Mr. Snyder's statements to law enforcement were voluntary. Finally, Mr. Snyder argues there was insufficient evidence of premeditation for the jury to convict him of first-degree murder. We affirm.

ISSUES

[¶2] We restate the issues as:

1. Did the circuit court err when it determined that Mr. Snyder was competent and fit to proceed?

2. Did the district court err when it determined Mr. Snyder's statements to law enforcement were voluntarily made?

3. Was there sufficient evidence of premeditation for a jury to convict Mr. Snyder of first-degree murder?

FACTS

[¶3] Mr. Snyder has a history of mental health issues, including commitments to mental health facilities. In June and July of 2012, Mr. Snyder was hospitalized two times due to paranoid and psychotic symptoms, as well as homicidal ideation. In 2014, he was again hospitalized and diagnosed with depression, a personality disorder, and substance abuse disorder.

[¶4] On May 23, 2018, Mr. Snyder reported a burglary at his home. Mr. Snyder believed the title to his truck and his social security card were stolen. Mr. Snyder suspected Mr. Erschabek of having committed the burglary. He told several acquaintances about his suspicions, and stated that Mr. Erschabek "needed to die."

[¶5] Sometime during the afternoon of May 23, Mr. Snyder called his mother and was upset about the burglary. Concerned about Mr. Snyder's behavior, his mother called in a welfare check. The following morning, on May 24, 2018, Goshen County Sheriff's Department Sergeant Kory Fleenor¹ went to Mr. Snyder's home to investigate the burglary. He also went to perform a welfare check on Mr. Snyder. Sergeant Fleenor observed that Mr. Snyder appeared pretty upset and concerned about the alleged burglary. During the welfare check he observed that Mr. Snyder was "very pleasant" and "was the clearest" he had seen Mr. Snyder. Sergeant Fleenor testified that he did not have any concern about Mr. Snyder harming himself or about his mental health.

[¶6] Later in the afternoon, Mr. Erschabek and his friend Justin Ellis were driving through Fort Laramie to pick up a mattress and stopped at Gavin Martin's residence. On their way to Mr. Martin's home, Mr. Ellis saw Mr. Snyder pass them in his truck traveling in the opposite direction. Mr. Snyder, after passing Mr. Ellis and Mr. Erschabek, immediately turned his vehicle around and followed Mr. Ellis to Mr. Martin's home and parked within two feet of Mr. Ellis’ vehicle.

[¶7] After parking, Mr. Ellis stayed in his vehicle while Mr. Erschabek exited and walked to the passenger side of Mr. Snyder's truck. Mr. Erschabek began speaking to Mr. Snyder through the passenger side window. Mr. Ellis testified that the conversation seemed to be one-sided as Mr. Snyder did not appear to be talking. Mr. Ellis then exited his vehicle, and Mr. Snyder exited his truck holding a large black knife. Mr. Snyder moved between the vehicles, lunged at Mr. Erschabek and stabbed him in the chest with the knife. At that point, Mr. Ellis tried to call 911, but Mr. Snyder pointed his knife at Mr. Ellis and told him to "put the phone down." Mr. Ellis complied, and Mr. Snyder got into his truck and left. When emergency medical personnel arrived at the home, Mr. Erschabek was dead. The stab wound to Mr. Erschabek's chest was over five inches deep, cut three ribs, and penetrated his heart. Sergeant Fleenor located a black fixed-blade knife amongst some trees in the front yard of Mr. Martin's residence.

[¶8] Mr. Snyder was arrested at his home later that day. When law enforcement arrived, Mr. Snyder had just taken a shower. After obtaining a search warrant, deputies searched Mr. Snyder's home and noticed that the towel in the bathroom was wet and there were fresh shavings in the sink.

[¶9] In the early morning hours of May 25, 2018, at approximately 1:30 a.m., Deputy Edwin Ochoa drove Mr. Snyder to the area where he indicated that he dumped the clothing he was wearing at the time of the murder. Before Deputy Ochoa and Mr. Snyder arrived at the location, Deputy James Kuhns had already recovered the items. Deputy Kuhns found "some clothes, a vest, boots ... [and] a knife holder – a sheath – that wraps around your leg" in a ditch off the roadway near the location that Mr. Snyder stated he dumped his clothes. The deputy testified that he recognized the boots as belonging to Mr. Snyder based on previous encounters.

[¶10] Beginning at around 9:45 p.m. on May 24, 2018, Sergeant Fleenor and Investigator Rick Scott interviewed Mr. Snyder for approximately four hours at the jail. During the interview, Mr. Snyder provided several different stories about what had happened that day. Eventually, Mr. Snyder claimed he stabbed Mr. Erschabek in self-defense and that Mr. Erschabek lunged at him and impaled himself.

[¶11] The State charged Mr. Snyder with first-degree murder on May 25, 2018. On May 29, 2018, before the preliminary hearing, Mr. Snyder's counsel challenged Mr. Snyder's competency and filed a motion pursuant to Wyo. Stat. Ann. § 7-11-303, requesting that Mr. Snyder be examined to determine his fitness to proceed. The circuit court issued an order suspending the proceedings and ordered the Wyoming State Hospital (WSH) to examine Mr. Snyder's competency.

[¶12] In her first forensic report dated July 30, 2018, Dr. Katherine Mahaffey concluded Mr. Snyder was not competent and recommended that he be transferred to WSH for restoration of his competence. On September 14, 2018, the circuit court issued a written order suspending the proceedings and, in accordance with Wyo. Stat. Ann. § 7-11-303(e), committed Mr. Snyder to WSH, and directed WSH to determine whether there was a substantial probability Mr. Snyder would regain his fitness to proceed.

[¶13] On January 28, 2019, Dr. Mahaffey completed her restoration evaluation and concluded that Mr. Snyder was competent. Mr. Snyder's counsel requested a hearing pursuant to Wyo. Stat. Ann. § 7-11-303(g) to contest Dr. Mahaffey's conclusion. The circuit court held an evidentiary hearing on February 19, 2019. Dr. Mahaffey and Dr. Maximillian Wachtel, a forensic psychologist, testified.² Dr. Mahaffey testified consistently with her report that Mr. Snyder has the level of capacity related to fitness to proceed and there is no additional time necessary to achieve competency. Dr. Wachtel testified that he only met with Mr. Snyder one time and he did not have enough "experience yet with Mr. Snyder to come up with an opinion that would override ... the evaluation done by [WSH] in terms of their diagnosis." He further testified that Dr. Mahaffey did a good job on her report and though he had concerns, he did not have enough information to contest her conclusions on Mr. Snyder's competency and fitness to proceed. The circuit court issued a written order concluding the State proved by a preponderance of the evidence that Mr. Snyder was fit to proceed.³

[¶14] On April 3, 2019, Mr. Snyder pled not guilty and not guilty by reason of mental illness (NGMI). The district court ordered Mr. Snyder undergo an NGMI evaluation pursuant to Wyo. Stat. Ann. § 7-11-304. Dr. Mahaffey, on behalf of WSH, evaluated Mr. Snyder. She concluded that at the time of Mr. Erschabek's death, Mr. Snyder "did not suffer from a mental illness or mental deficiency so severely abnormal as to have grossly and demonstrably impaired his perception or understanding of reality." In addition, she determined Mr. Snyder had the "capacity ... to appreciate the wrongfulness of his conduct [and] to conform his conduct to the requirements of law." On September 4, 2019, Mr. Snyder requested a second evaluation to be completed by Dr. Wachtel pursuant to Wyo. Stat. Ann. § 7-11-304(g). The district court conditionally granted the second evaluation, but there is nothing in the record to suggest it was ever completed.

[¶15] On November 1, 2019, Mr. Snyder filed a motion to suppress the statements he made to law enforcement during the four-hour interview on May 24 and 25, 2018. Mr. Snyder's motion asserted his statements were not voluntary in violation of the United States and Wyoming Constitutions. Generally, Mr. Snyder argued his "serious mental illness" affected the voluntariness of his statements when combined with the "coercive nature of the custodial interrogation." On December 3, 2019, the district court held an evidentiary hearing. Following the hearing, the district court concluded Mr. Snyder's statements were voluntary and denied his motion to suppress.

[¶16] A jury convicted Mr. Snyder of first-degree murder following a four-day trial ending on February 13, 2020. On June 2, 2020, the district court sentenced Mr. Snyder to life imprisonment according to law. Mr. Snyder timely filed notice of appeal to this Court.

DISCUSSION

A. Competency

1. Standard of Review

[¶17] Currently, we review a trial court's decision on a defendant's competency by a two-part...