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