Wyoming
How Long Is a Life Sentence in Wyoming? (2026 Guide)
Independently fact-checked against primary sources (last audited August 20, 2026). · Reviewed by the RecordingLaw editorial team. · Law checked current as of August 20, 2026. · 3 primary sources cited on this page. How we verify our legal content

In Wyoming, first-degree murder under Wyo. Stat. § 6-2-101 is punishable by death, life imprisonment without parole, or ordinary life imprisonment. For an adult offender sentenced to ordinary life imprisonment, Wyo. Stat. § 6-10-301(c) provides no parole eligibility at all unless the Governor first commutes the sentence to a term of years — the Wyoming Board of Parole has no independent authority to consider release. The 25-year figure sometimes associated with Wyoming life sentences applies only to offenders who were under 18 at the time of the offense, who become parole-eligible after 25 years or after commutation, whichever comes first.
This article was last reviewed and updated on March 17, 2026. All statutes, case law, and sentencing data have been verified against current Wyoming government sources.
In Wyoming, an adult sentenced to ordinary life imprisonment for first-degree murder has no path to parole at all unless the Governor commutes the sentence to a term of years — the Wyoming Board of Parole cannot act on an uncommitted life sentence. The 25-year figure sometimes cited for Wyoming actually applies only to juvenile offenders, who become parole-eligible after 25 years or gubernatorial commutation, whichever is first.
Wyoming is the least populous state in the nation, with fewer than 600,000 residents. Its murder rate is among the lowest in the country, and the state's prison population is correspondingly small. Yet Wyoming retains the death penalty on its statute books, even though it has not executed anyone since 1992.
Wyoming Life Sentence Statutes
Wyoming's criminal code defines homicide offenses with clear, direct language.
First-Degree Murder (Wyo. Stat. § 6-2-101): Murder committed with premeditation and deliberation, or murder committed during the commission of certain felonies (felony murder), including sexual assault, arson, robbery, burglary, escape, and kidnapping. First-degree murder is punishable by death, life imprisonment without parole, or ordinary life imprisonment. For an adult, an ordinary life sentence carries no parole eligibility unless the Governor commutes it to a term of years (Wyo. Stat. § 6-10-301(c)); the 25-year figure applies only when the offender was under 18 at the time of the crime.
Second-Degree Murder (Wyo. Stat. § 6-2-104): Purposely and maliciously killing another person without premeditation. Second-degree murder is punishable by 20 years to life in prison.
Manslaughter (Wyo. Stat. § 6-2-105): Unlawfully killing a human being without malice, either voluntarily in the heat of passion or involuntarily during the commission of an unlawful act. Punishable by a maximum of 20 years.
Aggravating factors (Wyo. Stat. § 6-2-102): Wyoming defines specific aggravating circumstances that can make a first-degree murder case eligible for the death penalty, including murder of a law enforcement officer, murder for hire, murder during the commission of specified felonies, and murder involving particularly heinous circumstances.
Parole Eligibility
Wyoming's parole system provides a structured path to release for life-sentenced inmates, though the wait is substantial.

Adults: An inmate sentenced to ordinary life imprisonment (not LWOP) for first-degree murder as an adult has no statutory parole-eligibility date. The Wyoming Board of Parole has no authority to consider the case unless the Governor first commutes the sentence to a term of years. Juveniles: An offender who was under 18 at the time of the offense becomes eligible for parole after gubernatorial commutation or after serving 25 years of incarceration, whichever comes first.
Second-degree murder: For life sentences imposed under second-degree murder, the minimum time before parole eligibility varies based on the specific sentence imposed by the judge.
Wyoming Board of Parole: The Wyoming Board of Parole is responsible for evaluating parole applications from eligible inmates. The board considers the nature of the offense, institutional conduct, participation in treatment and educational programs, risk assessment, victim impact, and the inmate's release plan.
Parole hearings: When a life-sentenced inmate reaches their eligibility date, the Board of Parole conducts a hearing. If denied, subsequent hearings are scheduled at intervals determined by the board. There is no guarantee of parole — some inmates serve well beyond their minimum eligibility date.
Conditions of parole: Parolees are subject to supervision conditions including regular reporting, restrictions on travel and association, drug testing, and compliance with all laws. Life parolees may be subject to extended or lifetime supervision.
Clemency
The Governor of Wyoming has the power to grant pardons, commutations, and reprieves. For inmates serving life sentences, executive clemency represents an alternative path to release beyond the parole system. However, clemency is rarely granted in murder cases.
Death Penalty — On the Books but Rarely Used
Wyoming retains the death penalty as a legal punishment, but it has been used extremely rarely in modern history.
Last execution: Wyoming's last execution was carried out on January 22, 1992, when Mark Hopkinson was put to death by lethal injection for ordering the murder of four people in the late 1970s. More than 30 years have passed since that execution.
Death row: As of 2026, Wyoming's death row population is zero. Dale Wayne Eaton, convicted of the 1988 kidnapping, sexual assault, and murder of 18-year-old Lisa Marie Kimmell, was Wyoming's last death-row inmate. His death sentence was vacated by a federal court in 2014, prosecutors withdrew their renewed bid for a death sentence in 2021, and he was resentenced to life without parole in March 2022.
Execution method: Wyoming uses lethal injection as its primary execution method.
Legislative efforts: There have been periodic efforts in the Wyoming legislature to abolish the death penalty, but none have succeeded. The state's conservative political culture and strong law-enforcement tradition have generally favored retention, even as the practical reality is that the death penalty is almost never sought or imposed.
Cost and practicality: Given Wyoming's very small number of capital cases, the cost of maintaining death penalty infrastructure relative to its use has been a point of discussion. The state's small population and low murder rate mean that capital cases are exceedingly rare.
Notable Life Sentence Cases in Wyoming
Dale Wayne Eaton — The Lisa Marie Kimmell Case
Dale Wayne Eaton was convicted of the 1988 kidnapping, sexual assault, and murder of Lisa Marie Kimmell, whose body was found in the North Platte River. The case went unsolved for over a decade until DNA evidence linked Eaton to the crime in 2002. He was originally sentenced to death, but a federal court vacated that sentence in 2014 over inadequate defense representation at the penalty phase. Prosecutors withdrew their renewed bid for a death sentence in 2021 after evaluators found Eaton incompetent for a capital sentencing hearing, and in March 2022 he was resentenced to life without parole plus consecutive terms on the related felony counts.
Matthew Shepard Murder (1998)
While the perpetrators of this crime were not sentenced to life in the traditional sense — Aaron McKinney received two consecutive life sentences without the possibility of parole as part of a plea deal that spared him from the death penalty, and Russell Henderson received two consecutive life sentences with no parole — the case had an enormous national and international impact.
Matthew Shepard's murder in Laramie, Wyoming, due to his sexual orientation, became a catalyst for hate crimes legislation across the country. The federal Matthew Shepard and James Byrd Jr. Hate Crimes Prevention Act was signed into law in 2009.
Mark Hopkinson — Last Execution
Mark Hopkinson was a prominent Evanston, Wyoming, businessman convicted of orchestrating the murders of Vincent Vehar, his wife Beverly, and their son John in 1979, as well as the murder of attorney Jeff Green. Hopkinson was sentenced to death and executed by lethal injection on January 22, 1992 — the last execution carried out in Wyoming.
Recent Legislative Changes
| Year | Change |
|---|---|
| 2023 | No major sentencing changes enacted |
| 2019 | Death penalty repeal bill narrowly failed in the legislature |
| 2014 | Juvenile sentencing reforms implemented following Miller v. Alabama |
| 1992 | Last execution carried out (Mark Hopkinson) |
Wyoming has seen relatively few changes to its life sentencing framework in recent years. The state's small population and low crime rate mean that legislative attention to criminal sentencing is less frequent than in larger states.
The most notable recent development has been the ongoing debate over death penalty abolition. In 2019, a bill to abolish the death penalty passed the Wyoming House of Representatives but was defeated in the Senate. The debate reflected a national trend of states reconsidering capital punishment.
Juvenile Life Sentences
Wyoming does not impose life without parole on juvenile offenders.
JLWOP banned: Consistent with the U.S. Supreme Court's rulings in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016), Wyoming ensures that juvenile offenders are not sentenced to mandatory life without parole. Individualized sentencing hearings are required for any juvenile facing a life sentence.
Transfer to adult court: Wyoming allows juveniles to be transferred to adult court for serious offenses. However, even when tried as adults, juvenile offenders receive sentencing consideration that accounts for their age, maturity, and rehabilitative potential.
Small numbers: Given Wyoming's small population and low crime rate, the number of juveniles facing murder charges in any given year is extremely small. The state has very few juvenile lifers.
Parole eligibility: Juvenile offenders sentenced to life in Wyoming are eligible for parole consideration, consistent with constitutional requirements that juveniles be given a meaningful opportunity for release based on demonstrated maturity and rehabilitation.
Historical Context
Wyoming's criminal justice history reflects its frontier heritage and small-state character.
Frontier justice: Wyoming Territory, established in 1868, dealt with crime in the context of a sparsely populated frontier. Vigilante justice and extrajudicial executions were part of the territory's early history, before formal legal institutions were fully established.
Statehood and early law: Wyoming became a state in 1890. Its criminal code was influenced by the legal traditions of its territorial era, with a strong emphasis on individual rights and limited government. The state's constitution, ratified in 1889, was one of the first in the world to grant women the right to vote — reflecting Wyoming's progressive streak on civil rights even as it maintained tough criminal penalties.
Death penalty history: Wyoming has carried out relatively few executions throughout its history. The state used hanging as its execution method until adopting lethal injection. Only a handful of executions were carried out in the 20th century, and none since 1992.
Modern era: Wyoming's criminal justice system today reflects its small, rural character. The state operates a small prison system, with the Wyoming Department of Corrections overseeing approximately 2,000 inmates. Violent crime rates are generally below the national average, though property crime and drug offenses have increased in some areas.
Political context: Wyoming is one of the most politically conservative states in the nation. Despite this, there has been bipartisan interest in criminal justice reform, including sentencing reform for non-violent offenses and exploring alternatives to incarceration. The death penalty debate has divided the legislature along less predictable lines than might be expected.
Wyoming Life Sentence at a Glance
| Category | Details |
|---|---|
| Life with parole minimum | None for adult offenders without gubernatorial commutation (Wyo. Stat. § 6-10-301(c)); 25 years applies only to juvenile offenders |
| LWOP available | Through death penalty statute (rarely applied) |
| Death penalty | On the books; last used 1992 |
| Last execution | January 22, 1992 (Mark Hopkinson) |
| Current death row population | 0 (as of 2026) |
| Juvenile LWOP | Banned |
| Parole board | Wyoming Board of Parole |
| Murder rate | Among the lowest in the U.S. |
| Key statutes | Wyo. Stat. §§ 6-2-101, 6-2-102, 6-2-104 |
Related Pages
Frequently Asked Questions
How long is a life sentence in Wyoming?
For an adult convicted of first-degree murder in Wyoming, an ordinary life sentence (as opposed to life without parole) carries no parole eligibility at all unless the Governor first commutes the sentence to a term of years — the Wyoming Board of Parole cannot act on its own. The 25-year figure applies only to offenders who were under 18 at the time of the offense. For second-degree murder, the minimum varies based on the judge's sentence.
Does Wyoming have the death penalty?
Yes, technically. Wyoming retains the death penalty in its statutes, but it has not been used since 1992, and as of 2026 no one is currently on death row. The state's last death-row inmate, Dale Wayne Eaton, was resentenced to life without parole in 2022. A 2019 bill to abolish the death penalty passed the House but failed in the Senate.
Can a juvenile get life without parole in Wyoming?
No. Juvenile life without parole is banned in Wyoming, consistent with the U.S. Supreme Court's rulings in Miller v. Alabama (2012) and Montgomery v. Louisiana (2016). Juvenile offenders must receive individualized sentencing and a meaningful opportunity for release.
What was the Matthew Shepard case?
Matthew Shepard was murdered in Laramie, Wyoming, in 1998 due to his sexual orientation. His killers, Aaron McKinney and Russell Henderson, both received life sentences without parole. The case became a national catalyst for hate crimes legislation, leading to the federal Matthew Shepard and James Byrd Jr. Hate Crimes Prevention Act in 2009.
How many people are on death row in Wyoming?
As of 2026, no one is on Wyoming's death row. Dale Wayne Eaton, convicted of the 1988 kidnapping, sexual assault, and murder of Lisa Marie Kimmell, was the state's last death-row inmate. His death sentence was vacated in 2014, prosecutors withdrew their renewed bid for a death sentence in 2021, and he was resentenced to life without parole in March 2022.
Updates
Corrected Wyoming's death-row population from 'one person' to zero: Dale Wayne Eaton, the page's cited death-row inmate, had his death sentence vacated in 2014 and was resentenced to life without parole in March 2022, so the state currently has no one on death row. Also replaced a dead Supreme Court citation link for Montgomery v. Louisiana and added the page's central, previously uncited parole statute (Wyo. Stat. § 6-10-301) to the citations.
Independently fact-checked against the cited primary sources; governing law re-checked for recent changes
Reviewed and approved by an editor
The Law Behind This Article
This article rests on the statutory provisions below, held in our own legal record and retrieved from the official source. Tap a section to read the operative text.
Wyoming Statutes, Title 6 - Crimes and Offenses - Chapter 2: Offenses Against the Person - Article 1: Homicide
§ 6-2-101Murder in the first degree; penalty.In force
(a) Whoever purposely and with premeditated malice, or in the perpetration of, or attempt to perpetrate, any sexual assault, sexual abuse of a minor, arson, robbery, burglary, escape, resisting arrest, kidnapping or abuse of a child under the age of sixteen (16) years, kills any human being is guilty of murder in the first degree. (b) A person convicted of murder in the first degree shall be punished by death, life imprisonment without parole or life imprisonment according to law, except that a person convicted of murder in the first degree who was under the age of eighteen (18) years at the time of the offense shall be punished by life imprisonment. (c) A person convicted of murder in the first degree in a case in which the state seeks the death penalty shall be sentenced in accordance with the provisions of W.S. 6-2-102.
Official text (excerpt) · last checked 2026-07-30 · Read the full text in our law library · Verify at wyoleg.gov
Cited in 111 court opinions in our collectionLatest citing opinion in our collection: 2026
Opinions citing this section in our collection:
- Engberg v. Meyer (Wyoming Supreme Court 1991, 820 P.2d 70)“…d of felony murder under W.S. 6-4-101 (Dec.1977 Repl.) (now W.S. 6-2-101): “(a) Whoever * * * in the perpetrat…”
- Bouwkamp v. State (Wyoming Supreme Court 1992, 833 P.2d 486)“…ormance of the felony for conviction of felony murder under Wyo.Stat. § 6-2-101 (June 1988). Instruction 15 requires…”
- Armstrong v. State (Wyoming Supreme Court 1992, 826 P.2d 1106)“…Armstrong was charged with first degree murder under W.S. 6-2-101 (1991). 2 At his arraignme…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
§ 6-2-102Presentence hearing for murder in the first degree; mitigating and aggravating circumstances; effect of error in hearing.In force
(a) Upon conviction of a person for murder in the first degree in a case in which the state seeks the death penalty, the judge shall conduct a separate sentencing hearing to determine whether the defendant should be sentenced to death, life imprisonment without parole or life imprisonment. The hearing shall be conducted before the judge alone if: (i) The defendant was convicted by a judge sitting without a jury; (ii) The defendant has pled guilty; or (iii) The defendant waives a jury with respect to the sentence. (b) In all other cases the sentencing hearing shall be conducted before the jury which determined the defendant's guilt or, if the judge for good cause shown discharges that jury, with a new jury impaneled for that purpose. The jury shall be instructed that if the jury does not unanimously determine that the defendant should be sentenced to death, then the defendant shall be sentenced to life imprisonment without parole or life imprisonment.
Official text (excerpt) · last checked 2026-07-30 · Read the full text in our law library · Verify at wyoleg.gov
Cited in 21 court opinions in our collectionLatest citing opinion in our collection: 2025
Opinions citing this section in our collection:
- Engberg v. Meyer (Wyoming Supreme Court 1991, 820 P.2d 70)“…ist of crimes which constitute aggravating circumstances in W.S. 6-2-102(h)(iv). The new version reads as follow…”
- Olsen v. State (Wyoming Supreme Court 2003, 67 P.3d 536)“…101 (a) (Michie 1997) and sentences of death imposed under Wyo. Stat. Ann. § 6-2-102 (Michie 1997), following a jury trial…”
- Harlow v. State (Wyoming Supreme Court 2003, 70 P.3d 179)“…101(a) (Michie 1997) and a sentence of death imposed under Wyo. Stat. Ann. § 6-2-102 (Michie 1997), following a jury trial…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
§ 6-2-104Murder in the second degree; penalty.In force
(a) Except as provided in W.S. 6-2-109, whoever purposely and maliciously, but without premeditation, kills any human being is guilty of murder in the second degree, and shall be imprisoned in the penitentiary for any term not less than twenty (20) years, or during life. (b) A person is guilty of murder in the second degree of an unborn child if: (i) The person purposely and maliciously, but without premeditation, kills or attempts to kill any human being; (ii) The human being was pregnant with an unborn child; and (iii) The unborn child dies as a result of the person's actions. (c) A person guilty of murder in the second degree of an unborn child shall be imprisoned in the penitentiary for any term not less than twenty (20) years, or during life.
Official text (excerpt) · last checked 2026-07-30 · Read the full text in our law library · Verify at wyoleg.gov
Cited in 63 court opinions in our collectionLatest citing opinion in our collection: 2026
Opinions citing this section in our collection:
- State v. Keffer (Wyoming Supreme Court 1993, 860 P.2d 1118)“…is present, the instruction should be given. NOTES [1] Wyo.Stat. § 6-2-104 (1988) provides as follows: Whoever…”
- Ryan v. State (Wyoming Supreme Court 1999, 988 P.2d 46)“…ed offense of murder in the second degree, in violation of Wyo. Stat. Ann. § 6-2-104 . [2] Ryan received a life sentence, a…”
- Barnes v. State (Wyoming Supreme Court 1993, 858 P.2d 522)“…dict convicting him of second degree murder in violation of W.S. 6-2-104 (1988) [1] and first degree arson for…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
§ 6-2-105Manslaughter; penalty.In force
(a) A person is guilty of manslaughter if he unlawfully kills any human being without malice, expressed or implied, either: (i) Voluntarily, upon a sudden heat of passion; or (ii) Involuntarily, but recklessly except under circumstances constituting a violation of W.S. 6-2-106(b). (b) Except as provided in W.S. 6-2-109, manslaughter is a felony punishable by imprisonment in the penitentiary for not more than twenty (20) years.
Official text (excerpt) · last checked 2026-07-30 · Read the full text in our law library · Verify at wyoleg.gov
Cited in 38 court opinions in our collectionLatest citing opinion in our collection: 2026
Opinions citing this section in our collection:
- State v. Keffer (Wyoming Supreme Court 1993, 860 P.2d 1118)“…uman being; (2) voluntarily, upon a sudden heat of passion. Wyo.Stat. § 6-2-105(a)(i) (1988). 3 The elements of second…”
- Vigil v. State (Wyoming Supreme Court 1993, 859 P.2d 659)“…stances constituting a violation of W.S. 6-2-106(b). Wyo.Stat. § 6-2-105 (1988) (emphasis added). The jury instr…”
- Cook v. State (Wyoming Supreme Court 1992, 841 P.2d 1345)“…hter is punishable by a term of not more than twenty years. W.S. 6-2-105(b) (1988). The aggravated robbery count…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
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Sources and References
- Wyo. Stat. § 6-2-101(law.justia.com)
- Wyo. Stat. § 6-2-104(law.justia.com)
- Wyo. Stat. § 6-2-105(law.justia.com)
- Wyo. Stat. § 6-2-102(law.justia.com)
- Wyoming Board of Parole(boardofparole.wyo.gov).gov
- *Miller v. Alabama*(law.cornell.edu).gov
- *Montgomery v. Louisiana*(law.cornell.edu)
- Wyo. Stat. § 6-10-301(wyoleg.gov).gov