John Leslie Chapman
2015 WY 15
| Wyo. | 2015Background
- John (Jon) Leslie Chapman pleaded guilty to attempted second-degree murder pursuant to a plea agreement that reduced charges and recommended a 25–50 year sentence within the statutory range.
- The district court accepted the plea and imposed 25–50 years. Chapman’s motion to withdraw his plea was denied and that denial was affirmed on direct appeal.
- Chapman filed a post-conviction petition raising multiple constitutional claims; it was denied and certiorari was denied.
- Within the Rule 35(b) time window after the Supreme Court’s action, Chapman moved to reduce his sentence to 15–25 years (later seeking 5–10 on appeal), citing age, poor health, time already served, good conduct, and family ties.
- The district court denied the Rule 35(b) motion without a detailed statement of reasons; Chapman appealed asserting abuse of discretion and that the sentence is cruel and unusual under the Eighth Amendment.
Issues
| Issue | Chapman’s Argument | State’s Argument | Held |
|---|---|---|---|
| Whether district court abused discretion in denying W.R.Cr.P. 35(b) motion | Motion presented new mitigating factors (age, health, time served, good behavior, family) meriting reduction | Court properly exercised discretion; Chapman offered little or no substantiation for claimed factors | No abuse of discretion — denial affirmed |
| Whether Chapman’s 25–50 year sentence is cruel and unusual under the Eighth Amendment | Sentence is disproportionate given age, health, parole prospects, and comparisons to other sentences | Sentence falls within statutory range and is not grossly disproportionate; Chapman supplied no reliable comparative or medical evidence | Sentence is proportionate; not cruel and unusual |
| Whether court had to articulate "good cause" when denying Rule 35(b) motion | District court failed to state good cause for denial | No Wyoming authority requires a specific showing of good cause in the order denying Rule 35(b) relief | No requirement to articulate "good cause" in the order; lack of detail is not an abuse of discretion |
| Whether court could grant Chapman’s requested reduced term below statutory minimum | Chapman sought significantly lower minimums (15, then 5 years) | Sentencing courts are bound by statutory minimums for attempted second-degree murder (20 years for underlying crime) | Requested reductions below statutory minimum could not be granted even if relief were warranted |
Key Cases Cited
- Solem v. Helm, 463 U.S. 277 (Eighth Amendment proportionality test)
- Oakley v. State, 715 P.2d 1374 (Wyo. 1986) (Solem test applied only when sentence is unusual or grossly disproportionate)
- Hodgins v. State, 1 P.3d 1259 (Wyo. 2000) (sentencing court may accept or reject info in Rule 35 context)
- Boucher v. State, 288 P.3d 427 (Wyo. 2012) (no requirement that denial explain specific supporting information)
- LeGarda-Cornelio v. State, 218 P.3d 968 (Wyo. 2009) (district court’s broad discretion in sentence reductions affirmed)
