The Wyoming Supreme Court affirmed a lower court's denial of a self-defense immunity claim in *Cody Joseph McCalla v. The State of Wyoming*, a case involving involuntary manslaughter charges stemming from a fatal altercation. The court issued its opinion on Feb. 5, 2026, upholding the district court's handling of McCalla's motion to dismiss.
Cody McCalla entered a conditional plea of no contest to involuntary manslaughter charges related to an altercation with Patrick Mudd that resulted in Mudd's death. The conditional plea allowed McCalla to preserve his right to appeal the district court's denial of his motion to dismiss, in which he asserted immunity from prosecution under Wyoming Statute § 6-2-602(f) on grounds that he acted in self-defense.
The case originated in the District Court of Sheridan County, where the Honorable Benjamin S. Kirven presided over the proceedings. McCalla's legal team, led by Ryan L. Wright of The Wright Law Firm in Cheyenne, argued that their client was entitled to immunity from prosecution under Wyoming's self-defense statute. The state was represented by the Wyoming Attorney General's office, including Deputy Attorney General Jenny L. Craig and Senior Assistant Attorneys General Kristen R. Jones and Samuel Williams.
Wyoming Statute § 6-2-602(f) provides certain protections for individuals who act in self-defense, potentially granting them immunity from prosecution in cases where their actions are deemed justified. McCalla's attorneys argued that his actions during the altercation with Mudd fell under this protection, making the prosecution improper under state law.
However, the district court found that McCalla's motion to dismiss failed to make a prima facie showing that he was entitled to immunity from prosecution. This determination required McCalla to proceed first at the hearing, a procedural decision that became one of the issues on appeal to the Wyoming Supreme Court.
McCalla presented three issues on appeal to the state's highest court, though the full details of these arguments are not completely outlined in the available court documents. The first issue challenged whether the district court erred in requiring McCalla to proceed first at the hearing after determining that his motion to dismiss alone did not establish a prima facie case for immunity.
The Wyoming Supreme Court's decision was issued under case number S-25-0111 during the October Term of 2025. The opinion was authored by Justice Fenn and decided by a panel that included Chief Justice Boomgaarden and Justices Gray, Fenn, and Jarosh, along with District Judge Causey sitting by designation.
Self-defense immunity statutes have become increasingly important in criminal law, as they can provide complete protection from prosecution for individuals who use force to protect themselves or others. These laws typically require defendants to show that their use of force was justified under the circumstances, often involving a burden of proof analysis that courts must carefully evaluate.
The procedural aspects of immunity claims can be complex, particularly regarding which party bears the initial burden of proof and how hearings should be conducted. Courts must balance the protection these statutes provide with ensuring that legitimate criminal cases can proceed through the justice system.
The conditional plea mechanism used in this case allows defendants to accept responsibility for charges while preserving their right to challenge specific legal rulings on appeal. This procedural tool can be valuable in cases where defendants believe they have strong legal arguments but want to avoid the uncertainty of a full trial.
The Wyoming Supreme Court's affirmance of the lower court's ruling means that McCalla's involuntary manslaughter conviction stands. The decision suggests that the state supreme court found no error in how the district court handled the self-defense immunity claim or the procedural requirements surrounding it.
Involuntary manslaughter charges typically arise when someone's actions, while not intending to cause death, result in another person's death through reckless or negligent conduct. The distinction between voluntary and involuntary manslaughter often centers on the defendant's intent and the circumstances surrounding the fatal incident.
The case highlights the ongoing legal complexities surrounding self-defense claims in Wyoming and other states with similar immunity statutes. As these laws continue to evolve, courts must carefully balance protecting legitimate self-defense actions while ensuring accountability for unlawful violence.
The opinion is subject to formal revision before publication in the Pacific Reporter Third, as noted in the court's standard disclaimer. This means that while the substance of the ruling is final, minor technical corrections may be made before the decision appears in the official reporter system.