State v. Mares, 335 P.3d 487

Edwin Mares, convicted of felony murder as a juvenile in 1995 (age 16), was originally sentenced to life imprisonment which, under the parole statutes then in effect, functioned as life without parole (parole only upon gubernatorial commutation).
In 2018 Mares filed a Rule 35 motion to correct an illegal sentence, arguing his mandatory life-without-parole sentence violated Miller v. Alabama (2012).
Wyoming amended its sentencing/parole statutes (effective July 1, 2013) to make juvenile life sentences eligible for parole after 25 years and to allow the Parole Board to consider juvenile lifers; the State and Mares agreed this amendment operates to convert his sentence to life with parole eligibility after 25 years.
The district court certified two questions to the Wyoming Supreme Court: (1) what test should Wyoming use to assess retroactivity of new constitutional rules on collateral review, and (2) whether Miller applies retroactively in Wyoming collateral proceedings. The State additionally raised mootness because Mares’s sentence had been converted by statute.
The Wyoming Supreme Court (Hill, J.) concluded the statutory amendment converted Mares’s sentence to life with parole eligibility after 25 years but, for judicial economy, answered the certified questions: (1) adopt the Teague v. Lane framework for collateral retroactivity in Wyoming; and (2) under Teague, Miller is a substantive rule and thus applies retroactively on collateral review.

Issue	Plaintiff's Argument (Mares)	Defendant's Argument (State)	Held
1) Which retroactivity test should Wyoming use on collateral review?	Use a broad state standard (Stovall/Linkletter or otherwise) or at least not be constrained to Teague.	Adopt the Teague framework for collateral retroactivity.	Wyoming adopts Teague v. Lane as the proper test for collateral retroactivity, while noting the state may apply it more liberally than the U.S. Supreme Court where appropriate.
2) Does Miller v. Alabama apply retroactively on collateral review?	Miller announces a substantive rule that removes mandatory juvenile LWOP from the State's power to impose, so it should apply retroactively.	Miller is procedural (not substantive) and not a Teague exception, so it should not apply retroactively.	Miller announces a substantive rule under Teague and therefore applies retroactively on collateral review in Wyoming.
3) Is Mares’s certified appeal moot because statutes already converted his sentence?	The statutory change does not fully remedy Miller’s individualized-sentencing requirement; questions remain justiciable.	The 2013 statutory amendments automatically converted Mares’s LWOP-equivalent sentence to parole-eligible after 25 years, making the Rule 35 challenge moot.	Although Mares’s sentence was converted by statute (so his original Rule 35 claim as framed may be unaffected), the court declined to dismiss the certified questions to provide statewide uniformity and guidance.

Teague v. Lane, 489 U.S. 288 (1989) (establishing the modern collateral-review retroactivity framework and its exceptions)
Miller v. Alabama, 567 U.S. 460 (2012) (holding mandatory life without parole for juveniles violates the Eighth Amendment and requires individualized sentencing consideration)
Schriro v. Summerlin, 542 U.S. 348 (2004) (summarizing Teague: new substantive rules apply retroactively; new procedural rules generally do not unless they are watershed)
Roper v. Simmons, 543 U.S. 551 (2005) (juveniles cannot be sentenced to death; differences between juveniles and adults relevant to Eighth Amendment analysis)
Graham v. Florida, 560 U.S. 48 (2010) (juveniles cannot be sentenced to life without parole for non-homicide offenses)
Danforth v. Minnesota, 552 U.S. 264 (2008) (state courts may adopt retroactivity rules different from federal habeas Teague, but cannot offer less protection than federal constitutional requirements)