John Robert Allen v. The State of Wyoming, 2026 WY 72

John Robert Allen pleaded guilty to three counts of first-degree sexual abuse of a minor after being charged with six counts. 1
Before the plea, the district court appointed the public defender, then questioned Allen's finances after he posted a $100,000 surety bond. 2
Allen said he had lost his job, lacked retirement accounts or borrowing capacity, and relied on his wife's assets and income. 3
The district court ordered Allen to sell his daughter's Ford Escape, appraise it, and deposit the proceeds with the clerk as a condition of continued appointed counsel. 4
Allen did not object, complied by appraising and depositing about $9,600, and later received consecutive 25-to-35-year sentences. 5
The Supreme Court reversed, holding Allen did not waive the issue by pleading guilty and the district court lacked authority to require the forced sale and deposit. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Allen waive his challenge by pleading guilty? 7	Allen's challenge concerns a pretrial property order, not guilt or plea validity.	Allen waived all nonjurisdictional issues by pleading guilty.	No; the guilty plea did not waive this unrelated challenge. 8
Could the court force sale of the Escape to fund appointed counsel? 9	The court exceeded statutory and rule authority by ordering liquidation before any judgment.	Allen could contribute, so the court could require sale and deposit as a condition of representation.	No; the court could assess ability to pay and order payments, but not force advance liquidation. 10

Dahl v. State, 462 P.3d 912 (Wyo. 2020) (guilty plea waives nonjurisdictional issues unrelated to voluntariness 11)
Popkin v. State, 429 P.3d 53 (Wyo. 2018) (guilty plea waives issues except jurisdiction and voluntariness 12)
Hagen v. State, 336 P.3d 1219 (Wyo. 2014) (plea waives challenge to conviction-related guilt issue 13)
Van Haele v. State, 90 P.3d 708 (Wyo. 2004) (guilty plea waiver serves finality and bars guilt-related claims 14)
Class v. United States, 583 U.S. 174 (U.S. 2018) (valid guilty plea relinquishes claims contradicting plea admissions 15)
Small v. State, 623 P.2d 1200 (Wyo. 1981) (early waiver rule referred to waiver of defenses 16)
Coleman v. State, 115 P.3d 411 (Wyo. 2005) (authority challenges are reviewed de novo even without objection 17)
Penner v. State, 78 P.3d 1045 (Wyo. 2003) (courts have only authority conferred by statute 18)
Mitchell v. State, 982 P.2d 717 (Wyo. 1999) (restitution/public defender reimbursement must follow statutory judgment-and-execution procedures 19)
Putnam v. State, 474 P.3d 613 (Wyo. 2020) (oral ruling controls over inconsistent written order 20)