Goetzel v. State

Summary

The Wyoming Supreme Court affirmed the denial of Darrel Goetzel's petition for post-conviction relief. The court held that res judicata barred his renewed double-jeopardy and ineffective-assistance claims because they had been raised or could have been raised in earlier proceedings, and he showed no good cause to avoid the bar.

Holdings

1. Res judicata barred Goetzel's double-jeopardy challenge because the claim had previously been litigated and, in any event, could have been raised in his direct appeal or earlier sentence-related proceedings.
2. The enactment or amendment of post-conviction statutes did not provide a basis to avoid res judicata when the substantive claims could have been raised under prior statutes and in prior proceedings.
3. Goetzel's ineffective-assistance claims did not constitute good cause to overcome res judicata.

Questions Presented

1. Whether res judicata barred Goetzel's post-conviction claims because the double-jeopardy and ineffective-assistance claims had been raised or could have been raised in earlier proceedings.
2. Whether the use of newly enacted or amended post-conviction statutes provided good cause to avoid res judicata.
3. Whether ineffective assistance of trial or appellate counsel constituted good cause to avoid res judicata.

Disposition

affirmed