Chad Faron Mebane v. The State of Wyoming

Summary

The Wyoming Supreme Court affirmed the denial of Chad Mebane’s motion to correct an illegal sentence under Wyoming Rule of Criminal Procedure 35(a). The court held that separate convictions and consecutive sentences for delivering a controlled substance on two different dates did not violate the federal or Wyoming constitutional protections against double jeopardy because each offense required proof of a distinct date and transaction.

Holdings

1. Separate convictions and sentences for two deliveries of a controlled substance do not violate double-jeopardy protections when the deliveries occurred on different dates and constituted separate criminal acts.
2. The sentence was not illegal because it did not impose multiple terms of imprisonment for the same offense or otherwise violate constitutional law.

Questions Presented

1. Whether separate convictions and sentences for two deliveries of a controlled substance occurring on different dates violate the Double Jeopardy Clauses of the United States and Wyoming Constitutions.
2. Whether the separate delivery convictions constituted an illegal sentence correctable under Wyoming Rule of Criminal Procedure 35(a).

Disposition

affirmed