Smith v. State (1989)
In Smith v. State, 773 P.2d 139 (Wyo. 1989), three jurors inadvertently observed the defendant, in handcuffs, being transferred from the jail to the courtroom.
The defendant moved for a mistrial, which motion was denied. The Court affirmed because "there was nothing in the record which identifies the three jurors, nor is there any evidence presented to show that appellant was prejudiced thereby." Id. at 141.
After characterizing the incident as "brief and incidental," we concluded that such an incident is not necessarily prejudicial, and to justify a new trial, actual prejudice must be shown. Id.