Bird v. Wyoming Board of Parole
Annotate this CaseDefendant was sentenced to two life sentences according to law for crimes he committed in the 1990s. In 2015, Defendant filed a complaint against the Wyoming Board of Parole and the Wyoming Department of Corrections pursuant to the Declaratory Judgment Act, alleging various constitutional violations. The district court dismissed Defendant’s claims. The Supreme Court affirmed, holding (1) Wyo. Stat. Ann. 7-16-2016(a)(i) does not violate Defendant’s equal protection rights because there is a legitimate state interest in treating prisoners differently with respect to the statute; (2) the Wyoming Department of Corrections’ good time policy does not violate Defendant’s equal protection rights because prisoners serving life according to law and prisoners serving a term of years sentence are not similarly situated; (3) the enactment of section 7-16-205(a)(i) did not impliedly repeal Wyo. Stat. Ann. 7-13-402(a); (4) the Wyoming Board of Parole did not violate the doctrine of separation of powers by enacting policies governing the commutation application procedure; (5) Defendant’s due process rights were not violated by the amendment to the commutation application procedure; and (6) the Wyoming Board of Parole’s amendment to the commutation application procedure did not violate Defendant’s constitutional protection against ex post facto laws.
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