Brunsvold v. State

In Brunsvold v. State, 864 P.2d 34 (Wyo. 1993), the defendant challenged the legality of a restitution order. 864 P.2d at 36. Two days prior to the district court's determination of his motion, Brunsvold was discharged from probation. Id. The district court initially granted Brunsvold's motion but then subsequently rescinded its order, and Brunsvold appealed. Id. On appeal we held that Brunsvold's discharge from probation terminated the district court's jurisdiction over him. 864 P.2d at 37. The key to the ruling was that the trial court no longer had jurisdiction over the defendant when it ruled on his motion challenging the legality of the restitution because he had been discharged from probation. 864 P.2d at 37.