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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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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.

Wyoming Supreme Court
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Manders v. State — Castle Doctrine Presumptions Do Not Extend to Driveway or Yard; Self-Defense Immunity Denied Where Victim Was Never Entering the Home

The Wyoming Supreme Court affirmed the denial of self-defense immunity to a man who shot and killed his neighbor during a dispute over property boundaries, holding that Wyoming’s castle doctrine presumptions under § 6-2-602(b) and (d) do not extend to outdoor areas such as driveways, and that a defendant’s subjective belief that an intruder was about to enter his home — without objective corroboration — is insufficient to trigger the statutory presumptions.

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