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Wyoming's "Lil' Miss Killer" ordered to undergo mental evaluation

Eaton convicted in 1988 murder of Lisa Marie Kimmel of Billings
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Posted at 5:24 PM, Apr 14, 2021
and last updated 2021-04-15 10:10:39-04

BILLINGS — Dale Wayne Eaton of Wyoming, originally sentenced to death for the murder of a Billings woman in what became known as the Lil' Miss Murder, could be headed back to death row. But first, Eaton will have to go through a mental evaluation to determine whether he is competent to be sentenced.

At a hearing Wednesday morning, Eaton, who is now 76 years old, was ordered to undergo a 30-day evaluation at the state hospital in Evanston. Eaton was convicted of the 1988 rape and murder of Lisa Marie Kimmel—who was 19 years old and had been on her way from Denver to visit her family in Billings when she was abducted. Eaton held her captive for several days on his rural compound before killing her and dumping her body was in the North Platte River.

The case went unsolved until 2002 when DNA linked Eaton to the crime. Kimmel's car with the license plate "Lil Miss" was found buried on his property. He was convicted and sentenced to death in 2004, but the sentence was overturned 10 years later when a federal appeals court ruled that Eaton hadn't received appropriate representation.

Prosecutors announced in 2019 that they would again seek the death penalty against Eaton. Then last year, the U.S. Supreme Court refused to hear Eaton's appeal, possibly clearing the way for his execution depending on whether he is found competent for sentencing.

Natrona County District Attorney Dan Itzen told Q2 that he expects it will take at least 30 days to do the evaluation on Eaton. If he is found competent, he would then return to district court to be resentenced.

Wyoming has not executed anyone since 1992.