Ronald Dale Anderson v. State

Summary

The Wyoming Supreme Court affirmed Ronald Dale Anderson’s convictions and concurrent sentences for two counts of third-degree sexual abuse of a minor after appellate counsel filed an Anders motion to withdraw and Anderson did not submit a pro se brief. The court granted counsel’s withdrawal, affirmed the district court’s judgment and sentence, and remanded for correction of clerical errors concerning the statutory subsection for one count.

Holdings

1. Appointed appellate counsel's Anders submission did not sufficiently identify potential errors or issues and did not fully demonstrate the required search of the record and law, but further briefing was unnecessary because the case was not sufficiently complicated to require it.
2. Clerical errors incorrectly stating the statutory subsection supporting one count should be corrected under W.R.Cr.P. 36 when the correct subsection is established by the change-of-plea transcript.

Questions Presented

1. Whether appointed appellate counsel satisfied the requirements for withdrawal under Anders v. California.
2. Whether the district court's judgment and sentence should be affirmed after review of the record and Anders brief.
3. Whether clerical errors incorrectly identifying the statutory subsection for one offense should be corrected under W.R.Cr.P. 36.

Disposition

reversed_and_remanded