Sanchez v. State

In Sanchez v. State, 841 P.2d 85, 88 (Wyo.1992), defense counsel refused to let the defendant testify in his own defense at trial. On appeal, the Court explained in order to ensure a defendant's waiver of his right to testify is valid, the district court should conduct an "on-the-record inquiry after the close of the defendant's case, although out of the jury's hearing, into whether a non-testifying defendant understands and voluntarily waives his right." Sanchez, 841 P.2d at 89.