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Wyoming

Wyoming Supreme Court
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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.

Wyoming Supreme Court
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In re AC and BI — Wyoming Supreme Court Affirms Neglect Finding, Upholds Admission of Post-Removal Hair Follicle Tests

The Wyoming Supreme Court affirmed a juvenile court’s finding that Father neglected his two minor children, holding the court did not abuse its discretion in admitting hair follicle test results collected after the date of alleged neglect, because the tests covered the relevant period and any challenge to their probative force went to weight rather than admissibility.

Wyoming Supreme Court
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Mostaert v. State — Wyoming Supreme Court Affirms Denial of Post-Conviction Motion to Return Seized Property

The Wyoming Supreme Court affirmed a district court’s denial of a convicted shoplifter’s Rule 41(g) motion for return of seized property, holding that the State overcame the post-conviction presumption favoring return by presenting credible testimony that the items were likely stolen—and clarifying Wyoming’s burden-shifting framework for such motions for the first time in the context of alleged stolen property.

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