Velasquez v. State, 2026 Wy. 11 (Wy. 2026)

The Supreme Court of Wyoming held that a trial court must hold a separate disposition hearing in probation revocation proceeding. The court stated in relevant part:

“Although Wyoming law does not require separate hearings for the adjudication and disposition phases of a probation revocation, each phase must be conducted in accordance with such law. The failure to do so constitutes plain error. Here, while the district court properly adjudicated the allegations that Mr. Velasquez violated the terms and conditions of his probation, the same cannot be said of the disposition phase of those proceedings. Because such procedural deficiencies call into question the fairness of the process, this Court must remand the matter to the district court to remedy those deficiencies, specifically by conducting the disposition phase in accordance with Wyoming law.”