Rhoads v. State, 431 P.3d 1130

Willott H. Rhoads IV was arrested for DWUI on October 23, 2016; he had three prior DWUI incidents (2006, 2008, 2011) with convictions in 2007, 2008, and 2012.
The State charged Rhoads with fourth-offense felony DWUI under Wyo. Stat. § 31-5-233(b) and (e), alleging four DWUIs within a ten-year lookback.
Rhoads moved to dismiss, arguing the ten-year lookback should run to the date of the underlying offenses (not convictions); alternatively he argued an equal protection violation if the lookback runs to conviction dates. The district court denied both motions.
Rhoads entered a conditional guilty plea reserving the right to appeal the lookback issue; the plea was accepted and he was sentenced.
The key statutory question: whether the § 31-5-233(e) ten-year lookback for a fourth DWUI measures to the date of the underlying offenses or to the dates of prior convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the § 31-5-233(e) ten-year lookback for a fourth DWUI is measured to the date of the underlying offense or to the date of conviction	Rhoads: "offense resulting in a conviction" means lookback to the date of the first offense (conduct)	State: language requires looking back to prior convictions (conviction dates)	Court: statute ambiguous but legislative text and history show legislature intended lookback to the underlying offense (conduct), not conviction dates; reversed conviction

Ramirez v. State, 386 P.3d 348 (Wyo. 2016) (interpreting amended § 31-5-233 and discussing lookback language change)
Seteren v. State, 167 P.3d 20 (Wyo. 2007) (prior construction focusing on convictions under earlier five-year version)
Parker Land & Cattle Co. v. Game & Fish Comm'n, 845 P.2d 1040 (Wyo. 1993) (definition of statutory ambiguity and interpretive approach)
In re Estate of Meyer, 367 P.3d 629 (Wyo. 2016) (rules on statutory interpretation and in pari materia construction)