Pfeil v. State
2014 WY 137
| Wyo. | 2014Background
- Pfeil pled guilty to second degree murder in 1997 under a plea agreement including court-ordered assessments and presentence costs.
- The district court imposed $1,000 for presentence confinement costs despite Pfeil being sentenced to the penitentiary.
- In 1998 Pfeil unsuccessfully moved to withdraw his plea; the appeal was dismissed for lack of jurisdiction.
- In 2013 Pfeil filed a pro se motion to withdraw plea and/or correct/reduce an illegal sentence; district court vacated the jail-cost portion but denied related relief.
- The district court ruled it lacked jurisdiction to withdraw Pfeil’s guilty plea after final judgment and sentence, and denied a reduction request.
- This Court affirmed, clarifying Rule 35 scope, Rule 32(d) withdrawal limits, and proper avenues to challenge DOC/BOP administration of a sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Notice of appeal sufficiency after district ruling | Pfeil’s notice identified the denial of his motion. | State argues notice failed to specify the exact order appealed. | Notice sufficiently invoked appellate jurisdiction. |
| District court authority to withdraw plea after final judgment | Rule 32(d) permits withdrawal for manifest injustice post-sentencing. | Final judgment precludes withdrawal; no manifest injustice shown. | Court lacked jurisdiction to withdraw after final judgment. |
| Authority to challenge DOC/BOP administration via Rule 35 | Rule 35 allows illegal-sentence challenges; DOC/BOP administration is relevant. | Rule 35 concerns illegal sentences, not administration challenges. | Rule 35 does not permit challenges to sentence administration; other remedies exist. |
| Timeliness of motion for sentence reduction | Requested reduction to time served; argued timely. | Rule 35(a) one-year window after final sentence; Pfeil filed late. | Late motion to reduce denied for lack of jurisdiction. |
Key Cases Cited
- McWilliams v. Wilhelm, 893 P.2d 1147 (Wy. 1995) (notice sufficiency when appeal identifies the designated portion of judgment)
- DeLoge v. State, 123 P.3d 573 (Wy. 2005) (deemed-denied rule not adopted in criminal cases; jurisdictional focus)
- Gomez v. State, 85 P.3d 417 (Wy. 2004) (appellate jurisdiction standards; leniency to pro se litigants)
- Patrick v. State, 108 P.3d 838 (Wy. 2005) (clarifies notice and timing rules in criminal appeals)
- Hitz v. State, 323 P.3d 1104 (Wy. 2014) (de novo review for jurisdiction questions; timing issues considered)