The Wyoming Supreme Court has upheld the revocation of bond for Tirso Munguia, one of the individuals charged in connection with the 2023 death of 16-year-old Angelina Harrison, Wyoming News Now report.
The high court ruled Thursday that the lower court acted within its discretion in revoking Munguia’s bond following a violation of its terms.
Munguia, who was 19 at the time of sentencing, had pleaded guilty to involuntary manslaughter as part of a plea agreement in which the Laramie County District Attorney’s Office agreed to recommend a sentence of eight to 12 years in prison. However, after Munguia made contact with the victim’s family—an act that violated his bond conditions—Goshen County District Judge Edward Buchanan imposed a sentence of 15 to 20 years without the possibility of parole. Munguia was also ordered to pay more than $11,000 in restitution and fees.
The contact occurred during a public fundraiser organized by Harrison’s family. According to court documents, Munguia was present at the well-publicized event and came into direct contact with family members. Though Munguia claimed he was unaware of the event’s nature and that the encounter was unintentional, the district court found otherwise.
In her opinion for the Wyoming Supreme Court, Chief Justice Kate Fox wrote that the district court’s bond revocation was supported by clear and convincing evidence.
“The district court did not abuse its discretion,” Fox stated. “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.”
The appeal also raised concerns about the legal standard for reviewing bond revocation decisions. While Wyoming case law has not previously defined the standard for such reviews, the court applied an “abuse of discretion” standard, consistent with other judicial determinations, such as probation revocations.
Justice Fox noted that willfulness was not a required element for revoking bond under Wyoming law.
“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,” she wrote.
The ruling marks a significant step in concluding legal proceedings stemming from the fatal shooting, which occurred on Jan. 9, 2023, when Munguia, riding as a passenger in a vehicle, discharged a firearm that struck and killed Harrison.
Munguia is one of three individuals sentenced in relation to the incident.
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