John Leslie Chapman v. The State of Wyoming
2013 WY 57
Wyo.2013Background
- Chapman was charged with attempted first degree murder, conspiracy to commit first degree murder, and later aggravated assault with habitual-criminal exposure to life; two cases were consolidated for trial.
- Chapman pled guilty to amended charge of attempted second degree murder under a plea agreement that dismissed conspiracy and aggravated assault charges; sentence recommended 25–50 years.
- The district court sentenced Chapman to 25–50 years and ordered restitution, but waived reimbursement of public defender fees.
- Chapman later sought to withdraw his plea alleging attorney coercion, misrepresentations about sentencing, and improper pressure; an evidentiary hearing was held and the motion was denied.
- On appeal, Chapman challenged the denial of his plea-withdrawal motion and the restitution award; the restitution appeal was argued notwithstanding timing issues.
- At the change-of-plea hearing, Chapman acknowledged rights and voluntariness; the State proposed amended charges and the defense outlined the plea terms including restitution and PD-fee considerations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the plea-withdrawal denial an abuse of discretion? | Chapman claimed coercion and misrepresentation invalidated the plea. | State contends the court properly weighed credibility and factual basis. | No abuse of discretion; findings supported; no manifest injustice shown. |
| Did the district court have authority to award restitution and waive public defender fees? | Restitution ordering plus waiver of PD fees was improper if not authorized by rule. | Court had authority under Rule 32.1 to prioritize restitution over PD fees and to order both. | Court had authority; restitution and PD-fee waiver upheld. |
Key Cases Cited
- Dobbins v. State, 2012 WY 110 (Wy. 2012) (review for abuse of discretion; factual findings preserved)
- Kruger v. State, 2012 WY 2 (Wy. 2012) (standard for appellate review of trial-court rulings)
- Jackson v. State, 2012 WY 56 (Wy. 2012) (deference to trial-court credibility determinations)
- Follett v. State, 2006 WY 47 (Wy. 2006) (manifest injustice and withdrawal of guilty plea standards)
- Ingersoll v. State, 2004 WY 102 (Wy. 2004) (manifest injustice framework and withdrawal timing)
- Yeager v. Forbes, 2003 WY 134 (Wy. 2003) (timeliness and jurisdictional concerns in appellate review)
- Cook v. Swires, 2009 WY 21 (Wy. 2009) (timeliness of notices of appeal and jurisdiction)
- Endris v. State, 2010 WY 73 (Wy. 2010) (illegal-sentence review and appellate consideration)
- Hite v. State, 2007 WY 199 (Wy. 2007) (illegality and sentencing-structure considerations)
- Sarr v. State, 2007 WY 140 (Wy. 2007) (utilizing appeal-scope to promote judicial economy)