Bryan Robinson v. The State of Wyoming, 454 P.3d 149

Trooper Carraher stopped Bryan Robinson on I‑80 after using the two‑second rule (measured twice with a stopwatch) and concluding Robinson was following a semi‑truck too closely.
During the stop the trooper noted an open sunroof in cold weather, food/trash indicating "hard travel," an overdue one‑way rental from Las Vegas, and inconsistencies in Robinson’s travel story (wrong competition date on the flyer).
Robinson twice denied prior drug arrests; a dispatch check revealed a prior misdemeanor marijuana citation, which Robinson had not disclosed.
Trooper Carraher detained Robinson further for a drug‑dog sniff; the dog alerted and a subsequent search recovered about ten pounds of marijuana.
Robinson pleaded guilty to possession (reserving the right to appeal the denial of his suppression motion verbally though the written plea did not expressly state the reservation); the district court denied suppression and this Court exercised discretion to review and affirm.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Conditional guilty plea validity	Robinson: oral record shows a conditional plea reserving suppression issue	State: Rule 11(a)(2) requires the reservation in writing	Court: Allowed appeal—transcript + prosecutor and court assent satisfied Rule 11(a)(2) under these circumstances
Stop for following too closely	Robinson: two‑second rule and trooper’s measurement were inappropriate; stopping distances show safe gap	State: Trooper applied two‑second rule twice with stopwatch; it is an accepted objective method to form reasonable suspicion	Court: Stop was reasonable—two‑second measurements gave particularized, objective suspicion of a §31‑5‑210(a) violation
Extension of detention for dog sniff	Robinson: facts were innocuous and did not justify prolonging the stop for a K‑9 sniff	State: Totality (overdue one‑way rental, inconsistent travel plans, limited stops, prior drug history, false denials) furnished reasonable suspicion to extend detention	Court: Denial of suppression affirmed—combined factors provided reasonable suspicion to detain for a dog sniff
Consideration of unpreserved pursuit claim	Robinson: Trooper’s pursuit before the stop violated the Fourth Amendment	State: That argument was not raised below	Court: Waived—appellate court refused to consider that unraised claim

Heien v. North Carolina, 574 U.S. 54 (2014) (traffic stop need only be supported by reasonable suspicion)
Arizona v. Arvizu, 534 U.S. 266 (2002) (reasonable‑suspicion analysis considers the totality of the circumstances; avoid divide‑and‑conquer)
United States v. Yasak, 884 F.2d 996 (7th Cir. 1989) (transcript can satisfy written‑reservation purpose for conditional pleas)
Walters v. State, 197 P.3d 1273 (Wyo. 2008) (Wyoming precedent permitting discretionary review when written reservation is lacking but record shows intent)
Allgier v. State, 358 P.3d 1271 (Wyo. 2015) (two‑second rule recognized as an appropriate method to assess following distance)
United States v. Hunter, 663 F.3d 1136 (10th Cir. 2011) (two‑second rule supports reasonable suspicion for following‑too‑closely stops)
United States v. Nichols, 374 F.3d 959 (10th Cir. 2004) (use of two‑second rule in reasonable‑suspicion analysis)
Faubion v. State, 233 P.3d 926 (Wyo. 2010) (Wyoming court excused strict compliance with written‑reservation requirement when record was clear)