The Wyoming Supreme Court says a local judge was wrong to release a Cody man from prison last year.
The high court’s ruling means Cameron Boni, 52, will likely need to return to the Wyoming …
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The Wyoming Supreme Court says a local judge was wrong to release a Cody man from prison last year.
The high court’s ruling means Cameron Boni, 52, will likely need to return to the Wyoming Department of Corrections and continue serving a nine- to 10-year sentence for a high-speed, multi-vehicle crash he caused in Powell.
Boni had raced into town at 143 mph in May 2023 while apparently suffering from delusions and paranoia; he reportedly told police that he believed he was being pursued by a group of conspirators who had planted a bomb in his Jetta. Boni hit four vehicles on Coulter Avenue before sliding to a stop, though no one wound up being seriously injured.
In the wake of the crash, serious questions were raised about Boni’s mental condition; a state psychologist suggested in 2024 that Boni was not guilty by reason of mental illness, finding his perception of reality was impaired to the point that he was unable to appreciate the wrongfulness of what he’d done.
However, then-Deputy Park County Attorney Jack Hatfield was unpersuaded and contended that Boni had been trying to kill himself and others. Hatfield sought to prosecute Boni as a “habitual criminal” due to two prior felony convictions and put up to 110 years of prison time on the table.
Boni ultimately entered a form of guilty plea and accepted the nine to 10 years on two felony counts of aggravated assault. However, he continued to insist he was innocent, saying in court that “the vehicle was actually taken out of my control” in a way he couldn’t explain.
Park County District Court Judge Bill Simpson said “all of us wish there was another outcome and another alternative,” but he approved the arrangement in 2024.
A revised sentence
Simpson had warned that any attempt to modify Boni’s sentence “would be deemed void on its face based on [the plea] agreement.” Last August, however, after hearing that Boni’s condition was deteriorating in prison, the judge suspended the prison term in favor of five years of supervised probation.
Simpson said the crimes Boni was convicted of were serious, “but appear to be the result of mental health issues” and he emphasized the need for rehabilitation.
“... Without any mental health treatment, he may continue on with the same criminal pattern,” Simpson wrote, saying Boni could get care out-of-custody that he wasn’t being provided in prison.
The decision came over the objection of county prosecutors, who argued Simpson lost the ability to revise the prison term once he accepted the deal.
Simpson agreed that the terms of the plea bargain prohibited him from making a “modification” to Boni’s sentence, but said they “did not prohibit a sentence reduction” like the one he ordered.
The Wyoming Attorney General’s Office and county attorney’s office, however, said a reduction is just a type of modification; Assistant Attorney General Donovan Burton charged that Simpson had essentially played a “word game” and “a game of ‘gotcha’” with prosecutors.
A rare reversal
In a rare move, the Attorney General’s Office challenged the decision by seeking a writ of review from the Supreme Court; in an even rarer move, the high court agreed to weigh in last fall.
Following months of briefings and arguments, the Supreme Court unanimously reversed Simpson’s reduction last week, effectively reinstating Boni’s nine- to 10-year sentence.
Simpson’s order reducing Boni’s sentence “was internally inconsistent and relied on a distinction between ‘reduction’ and ‘modification’ that it did not ultimately follow,” Chief Justice Lynne Boomgaarden wrote.
Further, Simpson’s decision was “inconsistent with the court’s own sentencing order stating it would ‘grant no further sentence reduction in this matter pursuant to [Wyoming Rules of Criminal Procedure] 35(b) except to correct an illegal sentence,’” Boomgaarden wrote.
While federal courts have been allowed to revise stipulated sentences under certain conditions, it’s unclear if that ruling applies to state courts — and even if it does, Boomgaarden said none of those limited circumstances were met in Boni’s case.
Other avenues
During oral arguments in March, Burton argued that Judge Simpson’s decision to release Boni felt like a medical parole or a compassionate release — decisions that are left in the hands of the Board of Parole or the governor rather than a court.
Boni’s defense attorney, Tim Blatt, later agreed there might be other ways to seek relief, but said they felt a sentence modification “was the most appropriate and quickest method to do it.”
Blatt argued it made sense for courts to have the authority to review sentences in cases like Boni’s, where he was reported to have lost weight and to have received no mental health treatment while in prison.
“... given what happened afterwards and after his sentence, I think it’s only just to have someone who has the opportunity to look at this and say, ‘Hey, we can’t continue this. There’s a problem here, and that problem is a pretty severe problem,’” Blatt said.
He argued the situation with Boni had changed drastically, but Burton said everyone was well aware of Boni’s mental condition prior to sentencing.
“This is not something that changed in prison to make this unpredictably unfair,” Burton said. “It was a basic fact of this case.”
While it wasn’t mentioned during the arguments, the concerns about weight loss and a lack of mental health care had also been raised while Boni was being held in the Park County Detention Center after his initial arrest.
“I don’t mean to sound callous, but this [mental health] is something that is common in our criminal justice system,” Burton said during oral arguments. “And if a district court had the authority to change any sentence because the offender was dealing with mental health problems, I think … this [Supreme] Court would have a lot of cases where this question is posed. And that would be a big change in the law.”
The high court ultimately ruled that judges don’t have that authority to revise stipulated sentences.
“While we appreciate his [Boni’s] effort to seek every possible avenue of relief, a motion for sentence modification or reduction was not available to him under the express terms of his plea agreement,” Boomgaarden wrote.
Next steps
Blatt told the Tribune the defense is reviewing the ruling and discussing next steps — including alternative relief measures that can be pursued through the Department of Corrections.
Meanwhile, Senior Deputy Park County Prosecuting Attorney Deputy Larry Eichele said he’s waiting for the Supreme Court to issue its official mandate, which will formally send the case back to Simpson.
No hearings have been scheduled as of Friday.