Brown v. State
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The Supreme Court affirmed the district court's denial of Defendant's motion to correct an illegal sentence and the issuance of a nunc pro tunc judgment conforming Defendant's written sentence to the court's oral pronouncement at his sentencing hearing, holding that there was no error in Defendant's sentence.
Defendant was convicted of conspiracy to commit first degree murder and sentenced to life in prison. Defendant later filed a motion to correct an illegal sentence, claiming that his written judgment and sentence was illegal under Hartley v. State, 460 P.3d 716 (Wyo. 2020). The district court denied the motion without a hearing and then issued a nunc pro tune judgment correcting the written sentence to conform it to the oral pronouncement. The Supreme Court affirmed, holding (1) the district court properly corrected Defendant's written sentence without a hearing; and (2) the sentence complied with Wyoming law.
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