Joseph Scott McNaughton v. State of Wyoming
2016 WY 112
| Wyo. | 2016Background
- McNaughton was charged with conspiracy to deliver methamphetamine after DCI/DEA wiretaps and seized text-message evidence from his girlfriend’s phone.
- Public defender was appointed; State made discovery available on a hard drive and offered in-person review at the U.S. Attorney’s Office; defense counsel did not review the full discovery before trial.
- The State offered a plea recommendation of 5–8 years; McNaughton rejected it and insisted on trial unless offered a misdemeanor/probation.
- At trial, the jury convicted McNaughton; he was sentenced to 4–8 years imprisonment.
- McNaughton moved for a new trial claiming ineffective assistance for failure to review discovery and failing to request a continuance; the district court denied the motion finding no proven prejudice.
- The Wyoming Supreme Court consolidated appeals and affirmed, holding McNaughton failed to prove prejudice required under Strickland/Lafler.
Issues
| Issue | McNaughton’s Argument | State’s Argument | Held |
|---|---|---|---|
| Was counsel ineffective for not reviewing all discovery and failing to seek continuance? | Counsel’s failure left him unaware of overwhelming evidence and prevented securing a more favorable plea; thus counsel was deficient and caused prejudice. | Even if counsel’s review was incomplete, McNaughton cannot show a reasonable probability of a better plea or that the court would have accepted it; any prejudice is speculative. | No ineffective assistance—prejudice not shown. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishes two-part test for ineffective assistance: deficiency and prejudice)
- Lafler v. Cooper, 566 U.S. 156 (prejudice in plea context requires showing offer would have been accepted, presented, accepted by court, and more favorable than trial outcome)
- Sen v. State, 301 P.3d 106 (Wyo. 2013) (courts may dispose of ineffectiveness claims on prejudice ground)
- Hibsman v. State, 355 P.3d 1240 (Wyo. 2015) (ineffective assistance claims are mixed questions reviewed de novo)
- Pendleton v. State, 180 P.3d 212 (Wyo. 2008) (failure to prove either deficiency or prejudice defeats claim)
- Galbreath v. State, 346 P.3d 16 (Wyo. 2015) (prejudice requires reasonable probability of different outcome)