Cameron Clayton Jennings v. State
2016 WY 69
| Wyo. | 2016Background
- Motel manager observed a female upset and crying outside her room, heard yelling and loud thuds from inside, then saw the couple leave in a yellow Chevy bus with Colorado plates; she called police reporting possible danger.
- Dispatcher broadcast a "family fight" call with vehicle description and passenger description; Detective Dunnuck located the bus and initiated a traffic stop.
- Upon approaching and opening the passenger window, officers smelled a strong odor of raw marijuana; officers then removed and handcuffed Jennings after he resisted; a search of the bus revealed large quantities of marijuana.
- Jennings was charged with conspiracy to deliver a controlled substance, unlawful possession, and obstruction; he moved to suppress the evidence obtained from the stop and search.
- The district court denied the motion, finding the stop justified by reasonable suspicion and alternatively under the community caretaker doctrine; Jennings entered conditional guilty pleas preserving the suppression issue and appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop violated the Fourth Amendment | Jennings: stop was unjustified because observed facts (arguing, crying, thuds, leaving quickly) are capable of innocent explanations and do not yield reasonable suspicion | State/Dunnuck: officer had specific, articulable facts (crying, yelling, thuds, rapid departure) creating reasonable suspicion of domestic violence or kidnapping | Court: stop was reasonable under Fourth Amendment; totality of circumstances gave rise to reasonable suspicion |
| Whether state constitutional claim requires separate analysis | Jennings invoked Article 1, §4 of Wyoming Constitution | State: suppression ruling under federal law sufficient; district court also relied on community caretaker function | Court: declined to address a separate state-constitutional analysis because Jennings did not develop it |
| Whether community caretaker function justified the stop/search | Jennings: challenged the stop generally (did not develop separate argument against caretaker rationale) | State: officer was performing community-caretaker duties to protect a possibly endangered passenger | Court: noted community-caretaker rationale but did not reach it because reasonable suspicion alone justified the stop |
Key Cases Cited
- United States v. Sokolow, 490 U.S. 1 (reasonable suspicion is less than probable cause)
- United States v. Arvizu, 534 U.S. 266 (totality-of-circumstances and rejection of ‘‘divide-and-conquer’’ analysis for reasonable suspicion)
- Cady v. Dombrowski, 413 U.S. 433 (community-caretaker doctrine recognizes noninvestigatory police functions)
- Owens v. State, 269 P.3d 1093 (Wyo. 2012) (standard of review for suppression rulings)
- Lovato v. State, 228 P.3d 55 (Wyo. 2010) (articulable facts and reasonable suspicion standard for stops)
- Garvin v. State, 172 P.3d 725 (Wyo. 2007) (evaluate how facts cohere into suspicion under Arvizu)