York v. State

619 P.2d 391 (Wyo. 1980).

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Nature of the Case

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Facts

York (D) pleaded not guilty to the charge of murder in the second degree. One month later, D changed his plea to not guilty by reason of mental illness or deficiency. Two psychiatrists testified that D did not have a mental illness or deficiency. During plea bargaining, the county attorney offered to reduce the charge to voluntary manslaughter and to secure a dismissal of an outstanding felony indictment in New Mexico. D refused the offer but agreed to plead guilty to involuntary manslaughter. The written plea agreement made no mention of the dismissal of the New Mexico charge. At a change of plea proceedings, the trial court requested both attorneys and D to state their understanding of the agreement. The trial court also questioned D in detail about his understanding of the consequences of pleading guilty to the lesser charge. After the plea, D sought post-conviction relief; he held that the State (P) failed to fulfill its portion of the plea bargain and that the change of plea proceedings violated his constitutional rights.