Kerry Eugene Garnett v. The State of Wyoming, 327 P.3d 749

Kerry Garnett, a pro se inmate, was convicted of first-degree felony murder and aggravated burglary and sentenced to life plus 20–25 years; prior appeals and collateral challenges have been unsuccessful.
In 2013 the Wyoming Department of Corrections transferred Garnett to a Virginia facility to serve his sentence.
Garnett filed a Motion to Vacate Judgment and Sentence and/or Motion to Correct Illegal Sentence, a Motion for Order to Show Cause, and a Motion for Hearing, arguing the transfer made his sentence illegal and requesting relief including ordering the Wyoming warden to show cause.
The district court dismissed Garnett’s filings as without merit and beyond its jurisdiction.
The State appellate court addressed whether the district court abused its discretion in denying Garnett’s motions, focusing on whether the transfer rendered his sentence "illegal."

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Garnett’s transfer to an out-of-state prison rendered his sentence illegal under W.R.Cr.P. 35/85	Garnett: Transfer to Virginia made his sentence illegal and warrants correction or show-cause relief	State/District Court: Transfer is an execution matter, not a defect in the sentence; court lacks jurisdiction to redress execution method	Held: Transfer did not make the sentence illegal; denial of motion to correct illegal sentence affirmed
Whether the district court had subject-matter jurisdiction to entertain Garnett’s Order to Show Cause / post-conviction-style relief	Garnett: Labels his filings as motions to vacate/correct and for show cause to challenge incarceration	State/District Court: No statutory or rule-based authority for such a show-cause procedure once conviction is final; court lacked jurisdiction	Held (majority): Motion dismissed as beyond jurisdiction and without merit; (concurring) appeal should be dismissed for lack of subject-matter jurisdiction rather than affirmed on merits

Mead v. State, 2 P.3d 564 (Wyo. 2000) (motion to correct illegal sentence entrusted to sentencing court's discretion)
Gould v. State, 151 P.3d 261 (Wyo. 2006) (Rule 85 focuses on the sentence itself, not execution of the sentence)
Kurtenbach v. State, 290 P.3d 1101 (Wyo. 2012) (trial court lacks post-final-judgment jurisdiction absent specific statute or rule)
Hitz v. State, 323 P.3d 1104 (Wyo. 2014) (substance of a motion, not its label, determines appropriateness/jurisdiction)
Rock v. Lankford, 301 P.3d 1075 (Wyo. 2013) (appellate review limited to jurisdictional questions where trial court lacked subject-matter jurisdiction)
Garnett v. State, 769 P.2d 371 (Wyo. 1989) (underlying conviction and prior collateral litigation history)