Wyoming Statutes

Wyo. Stat. § 1-11-209 (2026)

Further information after jury's retirement.

✓ current as of May 2026

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After the jurors have retired for deliberation, if there is a
disagreement between them as to any part of the testimony, or if
they desire to be informed as to any part of the law arising in
the case, they may request the officer to conduct them to the
court where information upon the matter of law shall be given.
The court may give its recollection as to the testimony on the
points in dispute, in the presence of or after notice to the
parties or their counsel.

Notes of Decisions

Cited in 21 cases (2 in the last 5 years), 1981–2024 · leading case: Chambers v. State, 726 P.2d 1269 (Wyo. 1986).

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Chambers v. State, 726 P.2d 1269 (Wyo. 1986). · cites it 20× “Section 1-11-209, W.S. 1977, permits a court to refresh the jury's recollection of *1276 trial testimony under certain limited circumstances.”

Snow v. State, 2009 WY 117 (Wyo. 2009). · cites it 12× “" It is easy to surmise that, as the jury began its deliberations, it had no idea what the allegation in count I (or count II or count III) was, and therefore asked the judge for guidance.”

Stephens v. State, 774 P.2d 60 (Wyo. 1989). · cites it 10× “Stephens seems to urge that § 1-11-209, W.S. 1977, creates an affirmative obligation on the part of the trial court to determine *70 the reason for the request of the jurors.”

Hunter Lee Hicks v. The State of Wyoming, 2021 WY 2 (Wyo. 2021). · cites it 4× “[¶28] Wyo. Stat. Ann. § 1-11-209 (LexisNexis 2019) permits the district court to refresh the jury’s recollection of trial testimony under certain circumstances.”

Travis Bogard v. The State of Wyoming, 2019 WY 96 (Wyo. 2019). · cites it 2× “21 Wyo. Stat. Ann. § 1-11-209 (LexisNexis 2019) allows a jury to request clarification of testimony if during deliberations a disagreement arises as to any part of the testimony, subject to certain procedures.”

Taylor v. State, 727 P.2d 274 (Wyo. 1986). · cites it 8× “We will reverse because the district court allowed the jury to view the testimonial videotape during deliberations without satisfying the requirements of § 1-11-209, W.S. 1977, infra, and Chambers v.”

Carlson v. Carlson, 888 P.2d 210 (Wyo. 1995). · cites it 8× “Wyo.Stat. § 1-11-209 (1988) reads as follows: After the jurors have retired for deliberation, if there is a disagreement between them as to any part of the testimony, or if they desire to be informed as to any part of the law arising in the case, they may request the officer to…”

Short v. Spring Creek Ranch, Inc., 731 P.2d 1195 (Wyo. 1987). · cites it 4× “The Shorts' other claim of error relates to the refusal of the trial court to reread portions of the trial testimony to the jury when request was made.”

Jackson v. State, 624 P.2d 751 (Wyo. 1981). · cites it 4× “He, also, makes assertion that the tapes contained reference to possible criminal conduct which was not the subject of the matter before the court.”

Heywood v. State, 2007 WY 149 (Wyo. 2007). · cites it 2× “5 Wyo. Stat. Ann. §§ 1-11-209 and 7-11-204 (LexisNexis 2007) clearly permit the judge further to instruct the jury after deliberations have begun when a question arises as to the evidence or the law, and in numerous cases over the years we have addressed the exercise of that…”

Nat. Gas Processing Co. v. Hull, 886 P.2d 1181 (Wyo. 1994). · cites it 2× “The Rissler opinion found plain error had been committed in the trial court’s failure (1) to return the jury to open court for instruction [Wyo.Stat. § 1-11-209 (1988) ], and (2) to make the jury instruction part of the record [Wyo.”

Britton v. State, 643 P.2d 935 (Wyo. 1982). · cites it 2× “” Section 1-11-209, W.S. 1977, does require the trial judge to answer questions from the jury in certain instances: “After the jurors have retired for deliberation, * * * if they desire to be informed as to any part of the law arising in the case, they may request the officer to…”

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