Steinfeldt v. State, 411 P.3d 418

Steinfeldt pleaded guilty to conspiracy to deliver methamphetamine and possession of marijuana with intent to deliver as part of a plea deal that capped the State's sentencing recommendation; other charges were dismissed.
Presentence investigation report filed November 2016 documented substance abuse history, depression, anxiety, suicidal ideation, and impairing symptoms.
Sentencing initially set for January 9, 2017; Steinfeldt obtained one continuance after retaining new counsel and sentencing was rescheduled to February 21, 2017.
Shortly before the rescheduled hearing Steinfeldt changed counsel again and requested a second continuance to obtain a psychological evaluation; the court denied the request.
On the day of sentencing the court reviewed a brief letter from Dr. Turlington recommending a full psychological evaluation but found no showing that the report would materially affect sentencing; court denied continuance, allowed allocution, and imposed concurrent terms of 13–20 years and 2–5 years.
Steinfeldt appealed, arguing denial of the continuance deprived her of presenting mitigation evidence under W.R.Cr.P. 32(c)(1)(C); the Wyoming Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by denying a continuance to obtain a psychological evaluation for sentencing mitigation	Steinfeldt: Rule 32(c)(1)(C) protects the right to present mitigating evidence; a psychological evaluation could produce mitigation that might reduce or alter sentence	State/Court: Court may require sentences to be imposed without unnecessary delay and has discretion to deny postponement absent a demonstrated important unresolved factor; Steinfeldt waited and had prior continuance	Denial was not an abuse of discretion; defendant failed to show the evaluation was an unresolved factor important enough to justify further delay

Griggs v. State, 367 P.3d 1108 (Wyo. 2016) (continuance standard and review for abuse of discretion)
Sincock v. State, 76 P.3d 323 (Wyo. 2003) (continuance rulings are discretionary and reviewed for manifest injustice)
Clearwater v. State, 2 P.3d 548 (Wyo. 2000) (continuance doctrine and appellate deference)
Grady v. State, 197 P.3d 722 (Wyo. 2008) (continuance review principles)
Hirsch v. State, 135 P.3d 586 (Wyo. 2006) (denial of second continuance to obtain evaluation affirmed where defendant previously delayed and failed to timely secure report)