Stice v. State

In Stice v. State, 799 P.2d 1204, 1208 (Wyo. 1990), the trial judge committed a similar error by failing to strictly comply with W.R.Cr.P. 15 (now W.R.Cr.P. 11), the trial judge did not inform Stice in open court of the minimum and maximum penalty for his crime. The error was deemed harmless because Stice had been made aware of the minimum and maximum penalties by statements his own attorney made to him in open court. Stice, 799 P.2d at 1208. In that case, the Court summarized the purposes for strict compliance with W.R.Cr.P. 15: "Those purposes are to assist the judge in making the constitutionally required determination that a defendant's plea is truly voluntary, to produce a complete record at the time the plea was entered of the factors relevant to this voluntariness determination, and to enable more expeditious disposition of the numerous and often frivolous post-conviction attacks on the constitutional validity of guilty pleas." (Stice, 799 P.2d at 1209.)