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Haynes v. State
288 P.3d 1225
Wyo.
2012
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Background

  • Appellant was adjudicated delinquent in juvenile court for acts that formed the basis of a later criminal charge.
  • On May 13, 2009, Appellant, then 16, was charged as an adult with first and second degree sexual abuse of a minor; first degree was later dismissed.
  • Appellant pled guilty to second degree sexual abuse of a minor on Oct 18, 2009, with sentencing deferred for participation in a treatment program.
  • On Mar 23, 2010, the State filed a delinquency petition alleging the same act; Appellant admitted the delinquency on Apr 12, 2010.
  • The district court accepted the guilty plea in the criminal case on Jun 1, 2010, sentenced Appellant to 10–15 years (suspended to 8 years' probation); Judgment entered Jun 28, 2010.
  • Nov 22, 2011, Appellant sought post-conviction relief claiming double jeopardy; this Court granted certiorari and reviews the double jeopardy claim on appeal.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether double jeopardy bars the criminal conviction for the same offense after delinquency adjudication Appellant asserts double jeopardy protections apply to bar the later criminal conviction State concedes error and agrees double jeopardy applies Yes; conviction reversed due to double jeopardy

Key Cases Cited

  • Breed v. Jones, 421 U.S. 519 (U.S. Supreme Court (1975)) (juvenile proceeding may attach jeopardy to bar later prosecution)
  • DeLoge v. State, 55 P.3d 1233 (Wyoming Supreme Court (2002)) (co-extensive protection of federal and Wyoming double jeopardy clauses)
  • Taylor v. State, 74 P.3d 1236 (Wyoming Supreme Court (2003)) (double jeopardy applies to jeopardy analysis in Wyoming)
  • Kitzske v. State, 55 P.3d 696 (Wyoming Supreme Court (2002)) (double jeopardy analysis in Wyoming decisions)
  • Snow v. State, 216 P.3d 505 (Wyoming Supreme Court (2009)) (plain-error standard for double jeopardy review)
  • Cook v. State, 1347 P.2d 1345 (Wyoming Supreme Court (1992)) (co-extensive constitutional protections referenced in analysis)
Read the full case

Case Details

Case Name: Haynes v. State
Court Name: Wyoming Supreme Court
Date Published: Nov 29, 2012
Citation: 288 P.3d 1225
Docket Number: No. S-12-0065
Court Abbreviation: Wyo.