“Knowingly” Re-defined: Fitzwater v. State of Wyoming and the Duty to Disclose Household Members & Joint Assets in Welfare Applications

Introduction

Sarah Renee Fitzwater appealed her 18 felony convictions for welfare fraud arising from omissions and misrepresentations on applications for SNAP, Medicaid, and LIEAP benefits between 2017 and 2023. The principal question on appeal was whether the State introduced sufficient evidence to prove that she “knowingly” (i) failed to list her children’s father, Matthew Wagy, as a household member and (ii) failed to disclose jointly-held Blue Federal Credit Union (BFCU) bank accounts and other assets. Sitting as fact-finder in a bench trial, the district court found the omissions intentional and material; the Wyoming Supreme Court (“WSC”) affirmed, thereby clarifying:

the breadth of the term “knowingly” under Wyo. Stat. Ann. § 42-2-112;
the evidentiary weight of circumstantial proof in welfare-fraud prosecutions; and
that joint assets and co-habitational relationships trigger mandatory disclosure duties even when the applicant frames the relationship as “separate.”

Summary of the Judgment

The Supreme Court (Jarosh, J.) unanimously affirmed Fitzwater’s convictions. Applying the familiar sufficiency-of-the-evidence standard, the Court held that:

The State’s documentation—voter registrations, school records, loan applications, social-media posts, utility information, and Fitzwater’s own admissions—permitted a reasonable inference that Wagy co-resided with her throughout the charged period.
Bank statements, BFCU corporate testimony, and linkage to Fitzwater’s spending patterns sufficed to show she had both knowledge of and access to the joint accounts.
Circumstantial evidence alone can satisfy the “knowingly” element; the district court was entitled to disregard conflicting defense evidence under the governing standard of review.

Because either omission (household member or joint assets) independently satisfied the statute, the Court affirmed all 18 felony counts without reaching other alleged omissions.

Analysis

1. Precedents Cited & Their Influence

a. Gonsalves v. State, 2024 WY 49

Clarified that “knowingly” carries its ordinary meaning of deliberate awareness, and that intent can be proven entirely by circumstantial evidence. The Court transplanted that definition here, observing that welfare-fraud statutes lack a special definition, thus the ordinary meaning controls.

b. Mathewson v. State, 2018 WY 81

Restated the sufficiency-of-the-evidence test in bench trials: the reviewing court accepts as true the State’s evidence and reasonable inferences, disregarding conflicting defense evidence. Fitzwater’s challenge lived or died on this standard, which the Court rigorously applied.

c. Other Authorities

Barrett v. State, 2022 WY 64 – quoted for the “knowingly” formulation.
Smith v. State, 2009 WY 2 – emphasized deference to fact-finder when faced with competing inferences.
General principles from Huckins, Stroble, and Faubion—all reinforcing the sufficiency standard.

Collectively these cases armed the Court with a robust doctrine of appellate deference and underscored that direct proof of mental states is rarely required.

2. Legal Reasoning

a. Statutory Framework

Sections 42-2-112(a) (SNAP) & (h) (Medicaid/LIEAP) criminalize either (i) “knowingly mak[ing] a false statement or misrepresentation” or (ii) “knowingly fail[ing] to disclose a material fact” in obtaining benefits. When the benefit value exceeds $500, felony treatment attaches (§ 42-2-112(k)(i)).

b. Household Concept

Applications defined “household” broadly (“all persons living with you”). By juxtaposing this language with compelling evidence of co-residence—shared addresses on official documents, back-yard camper testimony rebutted by police observation, and Facebook posts calling Wagy “hubby”—the Court concluded that Fitzwater had to know Wagy was a household member under program rules.

c. Asset-Disclosure Obligation

SNAP applications explicitly request assets “owned, jointly owned, or being purchased by household members.” The Court reasoned that even if Fitzwater were not a record owner, the accounts were “owned by a household member”—hence disclosure was mandatory. Her actual status as joint owner only fortified the knowing-omission finding.

d. Use of Circumstantial Evidence

The Court reaffirmed that bank deposits of child support, Chase credit-card payments matching Fitzwater’s admissions, and her ability to access funds via BFCU met the evidentiary threshold. Her initial denial, followed by reluctant admission, further evidenced consciousness of guilt.

3. Impact of the Decision

Clarifies “Knowingly” in Welfare Context: Prosecutors may rely almost exclusively on circumstantial indicators—joint deeds, voter registrations, banking patterns—to prove intent.
Household Definition Expanded: Co-habitation need not be full-time; partial or rotational residency, when evidenced by objective documentation, triggers inclusion on benefit applications.
Joint Assets = Disclosable Assets: Applicants can no longer shield resources behind nominal separations or informal arrangements. Any asset accessible to a household member must be reported.
Bench-Trial Sufficiency Affirmed: Provides a template for trial courts assessing credibility where romantic partners attempt to bifurcate finances and living arrangements.
Administrative Overpayment Calculations Endorsed: The Court implicitly validated DFS’s “rework the case using actual circumstances” methodology for restitution figures.

Complex Concepts Simplified

“Knowingly” – Acting with awareness; the person realizes what they are doing, unlike an honest mistake.
Circumstantial Evidence – Indirect proof (e.g., bank statements, shared addresses) that suggests a fact is true even without a witness saying so directly.
Household Member – Anyone who actually lives with the applicant, regardless of marital status or sleeping in a separate structure on the property.
Joint Asset – A bank account or property titled to more than one person; every owner has full rights to use the asset.
Overpayment – Benefits paid that the recipient was not entitled to receive, calculated by re-evaluating eligibility with accurate information.

Conclusion

Fitzwater v. State of Wyoming crystallizes the meaning of “knowingly” within Wyoming’s welfare-fraud statutes and amplifies applicants’ duties to disclose both co-residents and financial resources. By endorsing a robust use of circumstantial evidence and giving full effect to administrative definitions contained in benefit applications, the Court equips prosecutors and investigators with a clear roadmap for future fraud cases. Defense strategies that rely on technical living-arrangement distinctions or nominal asset separations will face heightened scrutiny. More broadly, the decision reinforces judicial deference to fact-finders in fraud prosecutions and underscores that welfare programs hinge on candid self-reporting—any deliberate deviation invites felony exposure.