Tony Serna v. The State of Wyoming, 305 P.3d 1142

Serna was charged with felony property destruction under Wyo. Stat. § 6-3-201(a)(b)(iii).
He entered a plea agreement to plead no contest; the State agreed to defer judgment and place him on five years of probation under § 7-13-301.
The district court accepted but did not enter the plea, and deferred judgment/sentencing placing Serna on supervised probation for five years.
Serna’s counsel was discharged after the deferral order; Serna proceeds pro se on appeal.
The State argues the appeal should be dismissed for lack of cogent argument and waiver due to the no contest plea.
The Supreme Court ultimately dismisses the appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal should be dismissed for lack of cogent argument and authority.	Serna’s brief fails to present valid contentions.	The pro se standard allows some leniency to discern issues.	Appeal dismissed for lack of cognizable arguments.
Whether a no contest plea forecloses appellate review of pre-plea defenses.	Serna argues possible pre-plea defenses and conspiratorial justification.	No contest plea waives nonjurisdictional defenses.	Waiver confirmed; appeal cannot be reviewed on those grounds.

Zanetti v. State, 783 P.2d 134 (Wyo. 1989) (no contest plea has same effect as guilty plea, waiving defenses)
Sword v. State, 746 P.2d 423 (Wyo. 1987) (no contest plea waives nonjurisdictional defenses)
Davila v. State, 831 P.2d 204 (Wyo. 1992) (discusses effect of pleas on review)
DeLoge v. State, 2012 WY 128 (Wyo. 2012) (leniency for pro se litigants in appellate briefing; discern issue)
Young v. State, 46 P.3d 295 (Wyo. 2002) (pro se entitlement to leniency when discerning issues)