WYOMING COURT RULES

102 instead issued the nunc pro tunc judgment to correct the inaccuracy in his written sentence without notice or a hearing because there being no change in his sentence, defendant had no constitutional right to a sentencing hearing. Brown v. State, 2021 WY 79, 489 P.3d 1162, 2021 Wyo. LEXIS 87 (Wyo. 2021). Nunc pro tunc judgment correcting the writ- ten sentence to conform it to the oral pro- nouncement was proper because the district court’s oral pronouncement of defendant’s sen- tence, a “term of natural life, according to law,” prevailed over his written sentence from the outset, and the nunc pro tunc judgment simply conformed defendant’s written sentence to the oral pronouncement. Brown v. State, 2021 WY 79, 489 P.3d 1162, 2021 Wyo. LEXIS 87 (Wyo. 2021). Applicability. — Action to which defendant objected, namely the imposition of consecutive terms rather than concurrent terms of incar- ceration, was a result of judicial, not clerical, action, and the asserted “mistake” was not a mistake at all, but the product of a written and signed plea agreement, which defendant ap- proved; therefore, W.R.Cr.P. 36 provided no relief. Beck v. State, 2005 WY 56, 110 P.3d 898, 2005 Wyo. LEXIS 64 (Wyo. 2005). Written judgment and sentence does not control over an oral sentence at variance with it. Where the transcript of the oral sen- tence and judgment and the mittimus are un- ambiguous and plain in directing a consecutive, not concurrent, sentence, and the written judg- ment and sentence contains an oversight and omission in this respect, it may be properly corrected by the trial court in a nunc pro tunc judgment and sentence. Lane v. State, 663 P.2d 175, 1983 Wyo. LEXIS 318 (Wyo. 1983).