Miller v. State, 424 P.3d 1284

Miller was arrested after officers found marijuana, paraphernalia, and methamphetamine in his vehicle; charged with multiple drug and related offenses.
After several changes of counsel and competency evaluation, Miller’s fourth counsel negotiated a plea: no contest to two marijuana counts in exchange for dismissal of remaining charges and recommended concurrent terms (3–8 years and 3–5 years); court accepted and sentenced accordingly.
Miller later filed a Rule 21 motion claiming his pleas were involuntary because fourth counsel erroneously told him he could still challenge speedy-trial and ineffective-assistance claims on direct appeal after entering no contest pleas.
At the evidentiary hearing, only trial counsel testified; she said Miller wanted immediate sentencing and release to be with his children and believed the plea was the best practical option given likely trial exposure; she also testified she thought (but was not certain) that some claims might survive the plea.
The district court denied relief, finding Miller failed to show prejudice under Strickland/Hill—i.e., he did not prove that, but for the erroneous advice, he would have insisted on going to trial. The Wyoming Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether incorrect advice that Miller could appeal speedy-trial and ineffective-assistance claims after no-contest pleas rendered pleas involuntary	Miller: Counsel told him he could still challenge those claims on appeal; this misinformation was determinative and made pleas involuntary	State: Miller’s own counsel testified Miller prioritized immediate sentencing, shorter exposure, and release; there is no contemporaneous evidence that appeal rights were the determinative factor	Court: Denied relief — Miller failed Strickland/Hill prejudice showing; no reasonable probability he would have insisted on trial

Strickland v. Washington, 466 U.S. 668 (establishes two-part ineffective assistance test)
Hill v. Lockhart, 474 U.S. 52 (applies Strickland to guilty-plea challenges)
Lee v. United States, 137 S. Ct. 1958 (courts should rely on contemporaneous evidence to assess whether counsel’s error changed plea decision)
Padilla v. Kentucky, 559 U.S. 356 (consequences like deportation can be central to a defendant’s plea decision)
Palmer v. State, 174 P.3d 1298 (Wyo. 2008) (prejudice inquiry considers probable outcome at trial as objective measure)
Osborne v. State, 285 P.3d 248 (Wyo. 2012) (standards for review of ineffective-assistance claims)
Rutti v. State, 100 P.3d 394 (Wyo. 2004) (Strickland/Hill framework for plea challenges)