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CHEYENNE – The Wyoming Supreme Court ruled Thursday that the state rightfully revoked the bond of one of the young men charged in the death of a 16-year-old girl in 2023.
Tirso Munguia, who was 19 at the time of his sentencing, pleaded guilty to involuntary manslaughter of Angelina Harrison as part of a plea agreement under which the Laramie County District Attorney's office agreed to recommend an eight- to 12-year prison sentence.
Despite the plea agreement, Munguia was sentenced to 15-20 years by Goshen County District Judge Edward Buchanan following contact with the victim's family, which violated his bond conditions.
Munguia was sentenced without the possibility of parole, and ordered to pay $6,625.52 in restitution, $5,000 in public defender’s fees and $275 in other fees.
Munguia appealed the sentencing, claiming the court abused its discretion in revoking his bond and the state violated its plea agreement.
The appeal went before the Wyoming Supreme Court, which ruled in favor of the district court in an opinion written by Chief Justice Kate Fox, published Thursday.
“The district court did not abuse its discretion in revoking Mr. Munguia’s bond, as its decision was supported by clear and convincing evidence,” Fox wrote. “The State also did not breach the plea agreement because Mr. Munguia’s bond violation triggered the cold plea provision, relieving the State of its obligation to recommend a reduced sentence.”
In his appeal, Munguia argued that the district court’s determination was not supported by clear and convincing evidence.
Abuse of discretion
Wyoming case law has not explicitly addressed the standard of review for bond revocation hearings, according to Fox's opinion. However, the state Supreme Court has consistently applied an abuse of discretion standard to similar determinations, such as probation revocations and bail bond forfeitures.
Because of this, the Supreme Court applied the abuse of discretion standard to Munguia’s case.
Judicial discretion entails a sound judgment that is exercised with regard to what is right under the circumstances, according to Fox’s opinion. It is applied without doing so arbitrarily or capriciously.
“A court abuses its discretion when it acts in a manner that exceeds the bounds of reason under the circumstances,” Fox wrote. “The ultimate issue for this Court to determine on appeal is whether the trial court could reasonably conclude as it did.”
Bond violation
Munguia argued that his contact with the victim's family was not willful, and, for that reason, he should not have been found in violation of bond.
“This Court has not held that a finding of willfulness is required to revoke bond,” Fox wrote. "However, to the extent willfulness is relevant to the district court’s decision in the context of bond revocations, it remains a finding of fact that will not be disturbed on appeal unless clearly erroneous.”
On Jan. 9, 2023, Munguia was a passenger in a vehicle in which he discharged a firearm, fatally wounding Harrison. He was later charged with involuntary manslaughter.
Munguia was one of three defendants sentenced in connection with Harrison’s death.
Following the initial incident, the victim’s family organized and publicized a fundraiser for their daughter’s foundation.
According to the facts considered by the Supreme Court, witnesses testified that the event was widely advertised and attendees had to pass a large red truck featuring the victim’s face to enter the lot.
At the event, Munguia came into contact with Harrison’s family.
“While the court recognized that the victim’s father may have escalated the situation, it emphasized that the initial responsibility for the contact ‘rest[ed] squarely with the defendant,’” Fox said. “Ultimately, the district court found that, given the circumstances, it was not credible that Mr. Munguia was unaware of the nature of the gathering, and concluded that his presence at the event and his contact with the victim’s family constituted a violation of his bond.”
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