The Wyoming Supreme Court issued an opinion Wednesday affirming the denial of an expungement petition for records from a dismissed criminal case, clarifying that Wyoming's expungement statute applies only to actual convictions.

In *Russell Lee Lynch v. The State of Wyoming* (2026 WY 8), the court held that Russell Lee Lynch was not eligible for expungement under Wyoming Statute § 7-13-1502 because his case was ultimately dismissed rather than resulting in a conviction.

The case stems from a 1979 incident in which Lynch and his brother took a truck in Laramie and drove it to Casper. Lynch initially pled guilty to felony Unauthorized Use of a Motor Vehicle, but his guilty plea was later withdrawn and the case was dismissed.

Decades later, Lynch filed a petition under Wyoming Statute § 7-13-1502 seeking expungement of his criminal records from the incident. The Albany County District Court, presided over by Judge Misha E. Westby, denied the petition. Lynch then appealed to the Wyoming Supreme Court.

The central legal question before the high court was whether deferred prosecutions are subject to expungement under Wyoming Statute § 7-13-1502. The statute specifically provides for expungement of felony convictions, but Lynch's case never resulted in a conviction since it was dismissed.

Writing for the court, Justice Gray explained the reasoning behind the denial. "Because Mr. Lynch's matter was dismissed, he has no felony conviction and is therefore ineligible for expungement," the court wrote. The opinion clarifies that Wyoming's expungement statute requires an actual conviction as a prerequisite for relief.

Lynch was represented by Amber Renee B. Ferguson of Pence and MacMillan LLC in Laramie, who argued the case before the Supreme Court. The State of Wyoming was represented by several attorneys from the Attorney General's office, including Deputy Attorney General Jenny L. Craig and Senior Assistant Attorneys General Kristen R. Jones and Kellsie J. Singleton, with Singleton presenting oral arguments.

The five-justice panel that decided the case included Chief Justice Boomgaarden and Justices Gray, Fenn, Jarosh, and District Judge Eames sitting by designation.

This ruling has significant implications for individuals in Wyoming who have had criminal cases dismissed after entering guilty pleas. The decision establishes that the state's expungement statute does not provide relief for dismissed cases, even when defendants initially entered guilty pleas to felony charges.

The distinction between dismissed cases and convictions is important in Wyoming's criminal justice system. While a conviction creates a permanent criminal record that can affect employment, housing, and other opportunities, a dismissed case technically does not result in a conviction. However, arrest records and court proceedings may still appear in background checks and public records searches.

Lynch's case illustrates the complexities that can arise when defendants seek to clear their records years or decades after criminal proceedings concluded. While his guilty plea was withdrawn and the case dismissed—typically a favorable outcome for a defendant—the existence of the court records continued to impact his life sufficiently that he sought legal relief through expungement.

The Wyoming expungement statute, § 7-13-1502, allows individuals with felony convictions to petition courts to seal their records under certain circumstances. The statute is designed to provide second chances for people who have completed their sentences and demonstrated rehabilitation. However, the Supreme Court's interpretation makes clear that the legislature intended the remedy to apply only to actual convictions.

This ruling may prompt legislative consideration of whether Wyoming's expungement laws should be expanded to cover dismissed cases or other situations where individuals face ongoing consequences from criminal charges that did not result in convictions. Some states have broader expungement statutes that cover arrests and charges that were dropped or dismissed.

For now, individuals like Lynch who have dismissed cases in their backgrounds must seek other forms of relief if they wish to address the continuing impact of their criminal records. This might include seeking clemency from the governor or pursuing other legal remedies, though options may be limited.

The decision also provides guidance to attorneys and courts handling similar expungement petitions. District courts can now cite this precedent when evaluating whether petitioners meet the statutory requirements for expungement relief.

Lynch's case began in 1979 but reached final resolution only this month, demonstrating how legal issues can persist for decades. The case serves as a reminder of the long-term consequences that can flow from criminal charges, even when those charges are ultimately dismissed.