2026 WY 84
Wyo.2026Background
- A jury convicted Goldie Beedy of exploiting a vulnerable adult, Harold Anderson, and the appeal challenges venue and restitution. 1
- Anderson was taken from his Glenrock home in Converse County to a Casper hospital in Natrona County, where doctors found he lacked decision-making capacity. 2
- While Anderson remained hospitalized, Beedy transferred title to his vehicle and mobile home, took possession of them, and later appeared at the Glenrock mobile home cleaning it and claiming it would be hers. 3
- The State charged Beedy in Converse County, and the district court denied her motion to dismiss for improper venue before trial. 4
- After conviction, the court ordered restitution for clothing bought by Anderson's guardian, finding his clothes were inaccessible because they remained in the mobile home under Beedy's control. 5
- The district court awarded $1,340.48 for clothing but declined restitution for work boots and guardian fees. 6
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was venue proper in Converse County? 7 | Beedy argued the offense occurred in Natrona County, where Anderson signed the titles. | The State argued the exploitation took effect in Converse County where Beedy controlled the property. | Yes. The evidence supported venue in Converse County. 8 |
| Was restitution for replacement clothing proper? 9 | Beedy argued the guardian could have retrieved Anderson's clothes, so no causal link existed. | The State argued Beedy's taking the mobile home also took Anderson's clothes and caused the loss. | Yes. The restitution award was within the court's discretion. 10 |
Key Cases Cited
- Hanson v. State, 571 P.3d 1282 (Wyo. 2025) (sufficiency-of-the-evidence review favors the State and jury inferences 11)
- Munoz v. State, 556 P.3d 238 (Wyo. 2024) (sufficiency-of-the-evidence review favors the State and jury inferences 12)
- Hultberg v. State, 549 P.3d 759 (Wyo. 2024) (sufficiency-of-the-evidence review favors the State and jury inferences 13)
- United States v. Calonge, 74 F.4th 31 (2d Cir. 2023) (venue is not an element of the crime 14)
- Aron v. Willey, 453 P.3d 1031 (Wyo. 2019) (venue rulings are reviewed for abuse of discretion 15)
- Nixon v. State, 994 P.2d 324 (Wyo. 1999) (venue rulings are reviewed for abuse of discretion 16)
- Morris v. State, 523 P.3d 293 (Wyo. 2023) (corpus delicti means the body of the crime 17)
- Merchant v. State, 4 P.3d 184 (Wyo. 2000) (venue may lie where the offense occurred or where the corpus delicti is found 18)
- McCone v. State, 866 P.2d 740 (Wyo. 1993) (venue can exist where criminal conduct takes effect 19)
- State v. Levand, 262 P. 24 (Wyo. 1927) (venue for libel was proper where the libel was circulated 20)
- Duke v. State, 571 P.3d 340 (Wyo. 2025) (restitution factual findings are presumptively correct and reviewed for abuse of discretion 21)
- Kuebel v. State, 446 P.3d 179 (Wyo. 2019) (clearly erroneous restitution findings and review of admissible evidence 22)
- Holliday v. State, 561 P.3d 335 (Wyo. 2024) (restitution sufficiency is reviewed for abuse of discretion 23)
- Freeman v. State, 448 P.3d 194 (Wyo. 2019) (restitution requires proximate cause and substantial-factor analysis 24)
- Alcaraz v. State, 44 P.3d 68 (Wyo. 2002) (remote conditions are not proximate causes for restitution 25)
- Layton v. State, 150 P.3d 173 (Wyo. 2007) (stealing a vehicle includes items contained inside it for restitution 26)