MOTION FOR FURLOUGH

Table of Contents

1. Caption
2. Defendant/Inmate Information
3. Grounds for Furlough
4. Statutory Authority
5. Proposed Conditions of Furlough
6. Risk Assessment
7. Supporting Documentation
8. Proposed Order
9. Certificate of Service

Caption

STATE OF WYOMING
IN THE DISTRICT COURT
[________________________________] JUDICIAL DISTRICT
[________________________________] COUNTY

MOTION FOR FURLOUGH / TEMPORARY RELEASE

The Defendant/Inmate, [________________________________], by and through undersigned counsel, respectfully moves this Honorable Court to grant or recommend a furlough / temporary release from [________________________________] (correctional facility), and in support thereof states as follows:

Defendant/Inmate Information

Grounds for Furlough

A. Compassionate Leave (Wyo. Stat. Ann. § 7-13-701)

☐ Immediate Family Member in Danger of Death
The Defendant's [________________________________] (relationship — must be spouse, child, parent, brother, or sister) is in danger of death at [________________________________] (medical facility). The family member's condition is [________________________________]. Medical documentation is attached as Exhibit [____].

☐ Funeral Services or Last Rites of Immediate Family Member
The Defendant's [________________________________] (relationship — must be spouse, child, parent, brother, or sister) passed away on [__/__/____]. Funeral services/last rites are scheduled for [__/__/____] at [________________________________].

B. Reentry Furlough Program (Wyo. Stat. Ann. § 7-13-702)

☐ Pre-Parole Release Reentry
The Defendant is about to be released on parole (parole date: [__/__/____]) and seeks reentry furlough to aid in reintegration as a productive member of society.

☐ Pre-Discharge Reentry
The Defendant is about to be released on final discharge (release date: [__/__/____]) and seeks reentry furlough for community reintegration.

Reentry Furlough Purposes:
☐ Maintaining relationship with immediate family members
☐ Securing employment
☐ Securing housing
☐ Participating in community treatment or rehabilitation programs
☐ Other purpose consistent with public interest and reintegration: [________________________________]

Type of Leave Requested:
☐ Escorted temporary leave of absence
☐ Unescorted temporary leave of absence

Statutory Authority

This Motion is filed pursuant to the following Wyoming statutes:

1. Wyo. Stat. Ann. § 7-13-701 — Defines "compassionate leave" as a temporary release to visit an immediate family member in danger of death or to attend funeral services/last rites of an immediate family member. Defines "immediate family member" as spouse, child, parent, brother, or sister.

2. Wyo. Stat. Ann. § 7-13-702 — Authorizes the Department to adopt rules providing for a reentry furlough program for inmates about to be released on parole or final discharge, designed to aid reintegration into society. The program may provide for escorted or unescorted temporary leaves for maintaining family relationships and other reintegration purposes.

3. Wyo. Stat. Ann. § 7-22-112 — Establishes nondelegation provisions ensuring that authority over inmate programs remains with designated officials.

Key Provisions:
- The Department determines inmate eligibility for furlough, compassionate leave, or community corrections participation
- Reentry furlough may be escorted or unescorted
- Purposes must be consistent with the public interest and the inmate's successful reintegration

Proposed Conditions of Furlough

Additional Proposed Conditions:

☐ Defendant shall remain at the designated destination at all times
☐ Defendant shall not consume alcohol or controlled substances
☐ Defendant shall not possess firearms or dangerous weapons
☐ Defendant shall comply with all federal, state, and local laws
☐ Defendant shall return to the facility by the designated date and time
☐ Defendant shall be escorted by WDOC personnel (if escorted leave)
☐ Defendant shall report to [________________________________] as directed
☐ Defendant shall maintain telephone contact with the facility
☐ Defendant shall not leave [________________________________] County without authorization
☐ Other: [________________________________]

Risk Assessment

1. Institutional Conduct: The Defendant has maintained [________________________________] conduct, with [____] disciplinary infractions in the past [____] months/years.

2. Security Classification: The Defendant is currently classified at [________________________________] level.

3. Program Participation: The Defendant has completed/is participating in: [________________________________].

4. Community Ties: The Defendant has [________________________________] (family, housing, employment in Wyoming).

5. Prior Furlough/Leave History: [________________________________].

6. Time Served: The Defendant has served [________________________________] of the imposed sentence.

7. Proximity to Release: The Defendant is [____] days/months from ☐ parole / ☐ final discharge.

8. Reintegration Plan: [________________________________] (if reentry furlough).

Supporting Documentation

☐ Exhibit A — Medical documentation for family member in danger of death
☐ Exhibit B — Death certificate, obituary, or funeral/service notice
☐ Exhibit C — Documentation establishing immediate family relationship
☐ Exhibit D — Institutional conduct and classification report
☐ Exhibit E — Program participation records
☐ Exhibit F — Community sponsor affidavit
☐ Exhibit G — Reentry plan (employment, housing, treatment)
☐ Exhibit H — Parole or release eligibility documentation
☐ Exhibit I — [________________________________]

Proposed Order

STATE OF WYOMING
IN THE DISTRICT COURT
[________________________________] JUDICIAL DISTRICT

ORDER GRANTING FURLOUGH / RECOMMENDATION FOR FURLOUGH

Upon consideration of the Motion for Furlough filed by the Defendant, [________________________________], and for good cause shown:

IT IS HEREBY ORDERED / RECOMMENDED that the Defendant be granted a ☐ compassionate leave / ☐ reentry furlough from [________________________________] (facility) for a period of [________________________________], commencing on [__/__/____] and concluding on [__/__/____], ☐ escorted / ☐ unescorted, subject to the following conditions:

1. [________________________________]
2. [________________________________]
3. [________________________________]

IT IS FURTHER ORDERED that the Wyoming Department of Corrections shall be notified of this Order/Recommendation.

Date: [__/__/____]

___________________________________________
District Court Judge

Certificate of Service

I hereby certify that on [__/__/____], a true and correct copy of this Motion for Furlough was served upon:

☐ County and Prosecuting Attorney, [________________________________] County — [________________________________]
☐ Wyoming Department of Corrections — [________________________________]
☐ Victim(s) / Victim's Advocate — [________________________________]
☐ Other: [________________________________]

Method of Service: ☐ Hand Delivery ☐ U.S. Mail ☐ Electronic Filing ☐ Email

___________________________________________
Attorney for Defendant
[________________________________]
[________________________________] (Wyoming State Bar Number)
[________________________________] (Address)
[________________________________] (Phone)
[________________________________] (Email)

Wyoming-Specific Notes

• Two Furlough Types: Wyoming provides compassionate leave (family emergency/death) and reentry furlough (pre-release reintegration).
• Immediate Family Definition: "Immediate family member" is strictly defined as spouse, child, parent, brother, or sister. This definition is narrower than some other states.
• Compassionate Leave Scope: Limited to visiting a family member in danger of death or attending funeral services/last rites.
• Reentry Furlough Scope: Designed for inmates about to be released on parole or final discharge, to aid reintegration as productive members of society.
• Escorted or Unescorted: The reentry furlough program may provide for either escorted or unescorted temporary leaves.
• Department Eligibility Determination: The Department of Corrections determines inmate eligibility for furlough, compassionate leave, or community corrections participation.
• Public Interest Standard: All furlough purposes must be consistent with the public interest and necessary for the inmate's successful reintegration into society.