James Joe Nordwall v. State, 361 P.3d 836

In 1994 Nordwall pled nolo contendere to a reduced second-degree sexual assault count under a plea agreement; the State dismissed the other counts charged in that information and recommended a 3–5 year sentence.
The county attorney in 1994 was aware of older police reports (circa 1992–1993) alleging Nordwall assaulted other women but had decided not to file charges on those matters at that time.
In 2013 a new investigation (triggered by a sex‑offender registration complaint) uncovered the earlier reports and statements, and an information was filed charging Nordwall with multiple first‑degree rape and first‑degree sexual assault counts based on incidents from the early 1990s.
After a jury trial Nordwall was convicted on seven counts (four first‑degree rape convictions and three first‑degree sexual assault convictions) and sentenced to lengthy terms of imprisonment.
Post‑trial Nordwall moved to dismiss, arguing (1) the 2013 prosecutions violated his Sixth Amendment speedy‑trial right because they should have been brought in 1994, and (2) the 1994 plea agreement included a promise not to prosecute prior sexual assaults; the district court denied dismissal and the Wyoming Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Speedy trial	Nordwall: speedy‑trial right attached in 1994 when he signed the plea and thus 19‑year delay violated the Sixth Amendment	State: speedy‑trial right attaches only upon arrest or formal charging for a specific crime; 2013 charges began the clock	Court held no speedy‑trial violation — right attached when charges were filed in 2013, not in 1994
Plea agreement breach	Nordwall: 1994 plea included an understanding (albeit unrecorded) that he would not be prosecuted for prior assaults	State: plea terms (on record) only dismissed the counts in the 1994 information; no recorded promise not to prosecute other incidents	Court held no breach — plea did not include a promise barring prosecution of crimes never charged in 1994; district court’s factual finding was not clearly erroneous

United States v. Marion, 404 U.S. 307 (1971) (Speedy Trial Clause attaches upon formal indictment/information or arrest)
Humphrey v. State, 185 P.3d 1236 (Wyo. 2008) (speedy‑trial right attaches upon charging or arrest)
Rhodes v. State, 348 P.3d 404 (Wyo. 2015) (standard of review for speedy‑trial claims)
Rutti v. State, 100 P.3d 394 (Wyo. 2004) (interpretation/enforceability of plea‑agreement terms regarding dismissal/refiling)
Cavender v. State, 860 P.2d 1162 (Wyo. 1993) (disputes over plea‑agreement conditions are factual matters reviewed for clear error)