State v. Naple

KITE, Justice.

[¶ 1] The district court dismissed with prejudice a controlled substances charge against Laura Jeanne Naple as a sanction for the State’s failure to comply with its discovery obligations. We granted the State’s petition for a writ of review and conclude the district court had the authority, under W.R.Cr.P. 16(d)(2), to dismiss the criminal charge with prejudice to sanction the State for violating a discovery obligation. That authority must, however, be used cautiously and only after consideration of the proper factors, including the reasons for the discovery violation, the…