Narrative Opinion Summary
The Supreme Court of Wyoming affirmed the district court's denial of a motion by the defendant, who sought to withdraw his nolo contendere plea post-sentencing. Initially charged with second-degree sexual assault and indecent liberties with a minor, a mistrial led to a plea agreement that dismissed the latter charge. The defendant later moved to withdraw his plea, arguing procedural deficiencies and lack of information on sex offender registration. The court found no abuse of discretion, as the defendant was fully informed of his rights and consequences during the plea process, and his motion lacked evidentiary support. The sex offender registration statute, W.S. 7-19-302, was deemed inapplicable due to the victim's age, and the court held no duty to inform on such regulatory matters. Additionally, claims regarding the statewide central registry were rejected since the relevant statutes pertain solely to adjudicated child abuse cases, which were not present here. Thus, the district court's decision to deny the motion without a hearing was upheld, concluding no manifest injustice occurred.
Legal Issues Addressed
Application of Sex Offender Registration under W.S. 7-19-302subscribe to see similar legal issues
Application: The statute did not apply to Johnson as the victim was over sixteen, and the court is not obliged to inform defendants of registration requirements since the statute is regulatory, not punitive.
Reasoning: Regarding W.S. 7-19-302 (1995), which mandates sex offender registration in Wyoming, it was determined that this statute did not apply to Johnson. Even if applicable, the court has no obligation to inform defendants of registration requirements, as established in Snyder v. State, which interpreted the statute as regulatory rather than punitive.
Central Registry of Child Protection Cases under W.S. 14-3-213subscribe to see similar legal issues
Application: The statute applies only to cases involving adjudication and disposition orders for child abuse or neglect, which was not applicable in Johnson's case.
Reasoning: It is determined that W.S. 14-3-213 is applicable solely to cases involving an adjudication and order of disposition for child abuse or neglect. In the present case, no such proceedings occurred that found Johnson guilty of abusing the victim.
Requirements for Holding a Hearing on Motion to Withdraw Pleasubscribe to see similar legal issues
Application: A district court can deny a motion to withdraw a plea without a hearing if the defendant's reasons are contradicted by the record, inherently unreliable, or merely conclusory.
Reasoning: A district court can deny a motion to withdraw a plea without a hearing if the defendant's reasons are either contradicted by the record, inherently unreliable, or merely conclusory.
Withdrawal of Plea Post-Sentencing under W.R.Cr.P. 32(d)subscribe to see similar legal issues
Application: A defendant must demonstrate 'manifest injustice' to withdraw a plea after sentencing, and the district court's discretion in denying such motions is not overturned absent abuse.
Reasoning: The court held that to withdraw a plea after sentencing, a defendant must demonstrate manifest injustice, per W.R.Cr.P. 32(d). The district court's discretion in denying such motions is not overturned unless there is an abuse of that discretion.