Emerging Adulthood Debate: Wyoming Court’s Stance On Life Sentences

The Wyoming Supreme Court has upheld the life sentences of Christopher Robert Hicks, rejecting his claim that mandatory life without parole for “emerging adults” amounts to cruel or unusual punishment under the Wyoming Constitution.

Hicks was 19 years old when he took part in two murders in Gillette in 2005. According to court records, Hicks and several others lived with 40-year-old Kent Proffit Sr., who was awaiting trial for the sexual assault of his teenage stepson, identified as B.C.

Proffit convinced Hicks and another roommate, Jacob Martinez, that their fellow housemate, Jeremy Forquer, was cooperating with law enforcement and should be killed. Hicks placed Forquer in a chokehold while Martinez tightened a rope around his neck. After disposing of Forquer’s body, the men later conspired with Proffit to kill B.C., the stepson, to prevent him from testifying in the sexual assault case.

Proffit told the group he would have them killed if they refused. Over Thanksgiving weekend, Hicks, Martinez, and a 15-year-old accomplice drove to B.C.’s home, where Martinez shot and killed the boy.

A Campbell County jury later convicted Hicks of first-degree murder and two counts of conspiracy to commit first-degree murder. Jurors rejected the state’s request for the death penalty, sentencing Hicks instead to three consecutive life terms without the possibility of parole.

In 2024, Hicks filed a motion to correct what he called “illegal sentences,” citing advances in neuroscience that show the brain continues to develop into a person’s early 20s. He argued that individuals under 21 share many of the same developmental traits as juveniles and should not face mandatory life sentences.

His defense team urged the court to extend the reasoning of several U.S. Supreme Court rulings — including Miller v. Alabama and Roper v. Simmons — which prohibit mandatory life without parole and the death penalty for offenders younger than 18.

The Wyoming Supreme Court disagreed. In a decision released this month, the justices found that those rulings draw a firm constitutional line at age 18 and that Wyoming’s Constitution does not provide broader protections for offenders above that age.

The Court cited its 2017 decision in Nicodemus v. State, which rejected similar arguments from an 18-year-old convicted murderer.

“The record does not support extending juvenile sentencing protections to adults who were 18 or older at the time of their crimes,” the Court wrote.

The ruling leaves Hicks’ three consecutive life-without-parole sentences in place. He is serving his sentence at the Wyoming State Penitentiary.

A defense representative expressed disappointment, saying the decision overlooks modern science.

“We’re not excusing what happened,” said public defender staff attorney Megan Lewis, who was not directly involved in the case. “But the research is clear — people under 21 are still developing impulse control and judgment. Courts around the country are beginning to recognize that.”