Ryan Russell Webster v. State
2016 WY 76
| Wyo. | 2016Background
- Ryan Webster stole a 2006 Cadillac Escalade in Thermopolis, WY, and was later arrested in Colorado after a multi-county pursuit.
- Wyoming filed charges in Laramie County (receiving stolen property) and Hot Springs County (larceny); detainers were placed while Webster was in Colorado custody under the Interstate Agreement on Detainers (IAD).
- Webster invoked the IAD and was transferred for disposition; the State failed to try him within the 180-day period, and the Laramie County charge was dismissed (the dismissal was treated as with prejudice under the IAD).
- Webster was then returned to Hot Springs County; that prosecution likewise was not tried within 180 days and was dismissed with prejudice; Webster returned to Colorado.
- The State later filed a new Hot Springs County charge alleging receiving stolen property (same statutory provision as the dismissed Laramie charge); Webster was extradited, convicted, and appealed.
- The Wyoming Supreme Court held that the earlier dismissal with prejudice in Laramie operated to bar reprosecution in Hot Springs under res judicata, reversing the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether double jeopardy barred the second Hot Springs prosecution | Webster: second prosecution constituted double jeopardy for same offense | State: jeopardy never attached in initial prosecutions because no jury was empaneled | Court: Double jeopardy did not apply because jeopardy had not attached (no jury), so constitutional double jeopardy protection not implicated |
| Whether a dismissal with prejudice bars later reprosecution (res judicata effect) | Webster: prior dismissals with prejudice preclude reprosecution of the same charge | State: prosecutions in different counties and differing charges mean reprosecution is permissible | Court: Dismissal with prejudice in Laramie met res judicata criteria (same parties, same subject/facts, same issues, same capacities) and therefore barred the later Hot Springs prosecution; conviction reversed |
Key Cases Cited
- Serfass v. United States, 420 U.S. 377 (1975) (jeopardy attaches in jury trials when jury is empaneled)
- United States v. Bilsky, 664 F.2d 613 (6th Cir. 1981) (dismissal with prejudice bars reprosecution)
- United States v. Oppenheimer, 242 U.S. 85 (1916) (res judicata applies in criminal cases and can bar subsequent prosecutions)
- Brown v. Ohio, 432 U.S. 161 (1977) (single course of conduct across jurisdictions may constitute one offense)
- United States v. Dionisio, 503 F.3d 78 (2d Cir. 2007) (res judicata or collateral estoppel does not by itself establish that jeopardy attached)