Cameron Curtis Hagen, 336 P.3d 1219

Hagen, convicted of aggravated assault, was housed in a community corrections facility in Casper and left for work on May 14, 2012, failing to report and visiting unauthorized locations before returning after reporting time.
Hagen was charged with escape under Wyo. Stat. Ann. §§ 7-18-112 and 6-5-206(a)(i); the State charged him for leaving official detention.
Hagen entered an unconditional nolo contendere plea to escape; the district court sentenced him to 15 to 24 months in prison.
Hagen filed four district court motions, including a motion to withdraw his plea, a motion for release pending appeal, a motion to correct illegal sentence, and a motion for sentence reduction; the latter three were denied.
The consolidated appeals challenged the legality of Hagen’s sentence and conviction, which the Supreme Court ultimately affirmed.
The court analyzed whether the underlying detention status and good-time credits affected the legality of the escape conviction and whether a Rule 35 motion could challenge the validity of the conviction itself rather than the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hagen’s escape conviction is illegal given he had completed his underlying sentence and was not detained.	Hagen contends he was not properly detained and his good-time recalculation after a DOC policy change violated ex post facto.	State maintains the plea waives such challenges to the underlying conviction and that the sentence remains legal despite detention status.	No illegal sentence; conviction valid and affirmed.
Whether Hagen’s challenge to the conviction via motion to correct an illegal sentence was proper.	Hagen argues the sentence was illegal due to miscalculated good-time credits.	A motion to correct illegal sentence cannot attack the validity of a conviction.	Motion to correct illegal sentence properly denied; conviction challenge not cognizable there.

Gee v. State, 317 P.3d 581 (Wy. 2014) (illegal sentence standards; scope of Rule 35 challenges)
Lunden v. State, 297 P.3d 121 (Wy. 2013) (motions to correct illegal sentence do not attack conviction)
Bird v. State, 39 P.3d 430 (Wy. 2002) (plea validity; scope of challenges after guilty plea or nolo contendere)
Ochoa v. State, 848 P.2d 1359 (Wy. 1993) (voluntariness and validity issues post-plea)
Cothren v. State, 310 P.3d 908 (Wy. 2013) (credit for time served and whether improper credit yields illegal sentence)
Whitten v. State, 110 P.3d 892 (Wy. 2005) (discretion in evaluating motions to correct illegal sentence)
Sweets v. State, 36 P.3d 1130 (Wy. 2001) (legal standard for review of motion to correct illegal sentence)
Van Haele v. State, 90 P.3d 708 (Wy. 2004) (plea and conviction challenges; scope of Rule 35)
Steele v. State, 620 P.2d 1026 (Wy. 1980) (nolo contendere plea effects; waiver of issues)