Garcia v. State — Rule 35(b) denial required no detailed explanation
The Wyoming Supreme Court held that a court need not explain a Rule 35(b) denial in detail and that rehabilitation alone does not require a sentence reduction.
Uncategorized
Sentencing
Uncategorized
Melber v. State — Wyoming Supreme Court denies credit for time held on independent Iowa charges
The Wyoming Supreme Court held that time spent jailed on independent Iowa charges did not count toward a Wyoming sentence and declined to review a later counsel order that was not identified in a notice of appeal.
Uncategorized
Gauna v. State — Presentence credit limited across separate cases
The Wyoming Supreme Court held that jail time already credited to a probation-revocation sentence did not have to be credited again in two separate felony cases.
Uncategorized
Hughes v. State — Plea Agreement “Sentencing Cap” Is a Non-Binding Recommendation, Not a Stipulated Sentence Under W.R.Cr.P. 11(e)(1)(C)
The Wyoming Supreme Court unanimously affirmed consecutive sentences for a former Casper police officer who pleaded guilty to five counts of aggravated assault and battery following a prolonged armed standoff, holding that a plea agreement capping the State’s “sentencing argument” was a non-binding recommendation under W.R.Cr.P. 11(e)(1)(B)—not a stipulated sentence under 11(e)(1)(C)—and that Wyoming district courts need not make specific findings when deviating from a sentencing recommendation.