Stephens v. State
Wyoming Supreme Court
734 P.2d 555 (1987)
Roy Dale Stephens (defendant) let his friend Harry Van Buren stay overnight after Van Buren told him he had just burglarized Yellowstone Electric; Stephens said he "didn't want to hear about it" and went to bed, without calling police or telling Van Buren to leave. The next day the two unsuccessfully searched for a truck part, after which Van Buren gave Stephens $100 toward a car purchase. When police later questioned Stephens, he initially denied any knowledge of the burglary but eventually admitted Van Buren had told him about it. Stephens was convicted of being an accessory after the fact to the burglary and appealed.
Whether a defendant is guilty of being an accessory after the fact when he merely allows a known offender to stay overnight and passively denies knowledge of the crime, without any affirmative act to help the offender evade detection.