Roman G. Sanchez v. State
2017 WY 70
| Wyo. | 2017Background
- Sanchez was charged with second-degree murder, pleaded no contest in 2008 after advisements, and the district court accepted the plea; no written plea agreement appears in the record.
- Before sentencing Sanchez filed (and later withdrew) a pre-sentence motion to withdraw his plea asserting he felt pressured and was unaware of consequences; at that hearing the prosecutor stated the State would not file other charges if sentencing occurred on second-degree murder.
- At sentencing the court imposed life with possibility of parole; Sanchez did not appeal and later sought sentence reconsideration, which the court found it lacked jurisdiction to consider.
- In 2014 the State and defense jointly moved to correct an illegal sentence, stipulating a plea agreement expectation that parole eligibility would be possible; the district court amended Sanchez’s sentence to 45 years to life with possibility of parole.
- In December 2015 Sanchez filed a post‑sentence motion to withdraw his no contest plea (and for sentence reduction/resentencing); the district court denied the motion and Sanchez appealed only the denial of the motion to withdraw his plea.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court had subject‑matter jurisdiction to entertain Sanchez’s post‑sentence motion to withdraw his plea | Sanchez: court abused discretion; plea involuntary because counsel failed to inform court of plea bargain | State: Sanchez’s motion was untimely and the court lacked jurisdiction to hear it | Court: Motion untimely because conviction was final (no appeal); district court lacked jurisdiction; appeal dismissed |
Key Cases Cited
- Neidlinger v. State, 230 P.3d 306 (Wyo. 2010) (post‑sentence plea withdrawal untimely after conviction final deprives district court of jurisdiction)
- Shue v. State, 367 P.3d 645 (Wyo. 2016) (motions to withdraw plea filed long after conviction final must be dismissed for lack of jurisdiction)
- In re HLL, 372 P.3d 185 (Wyo. 2016) (appellate court’s jurisdiction limited to jurisdictional issues when lower court lacked subject matter jurisdiction)
- Nixon v. State, 51 P.3d 851 (Wyo. 2002) (recognizing necessity of a time limit for post‑sentence plea withdrawal to give effect to finality)
- Ultra Res., Inc. v. Hartman, 346 P.3d 880 (Wyo. 2015) (law‑of‑the‑case doctrine preserves consistency of judicial decisions)