David Lee Smith v. the State of Wyoming

Summary

The court held that the district court violated a clear rule of law by determining the willfulness of probation violations during the adjudicatory phase rather than the dispositional phase. The error did not constitute plain error because Smith had opportunities to present his account of the violations, the court considered that information before sentencing, and he failed to show material prejudice. The court therefore affirmed the revocation of probation and reimposition of the underlying sentence.