Carl Wayne Allgier v. State, 358 P.3d 1271

Trooper Tegdesth stopped a northbound Jeep for following too closely (about one car length / ~50 feet behind another car) and a cracked windshield; video recorded the encounter.
Appellant Allgier was front-seat passenger; he acted agitated, refused to exit, then removed and tossed his jacket into the back seat when the trooper opened the door.
During a pat-down the trooper found a pocket knife; Allgier then appeared to have a seizure and was handcuffed while an ambulance was summoned.
The trooper retrieved the tossed jacket, looked into an open pocket seeking medication/assistance or to check for weapons, and observed a Colorado medical-marijuana bottle labeled to Allgier containing suspected marijuana.
A subsequent vehicle search uncovered felony quantities of marijuana; Allgier moved to suppress the jacket and vehicle evidence, lost in district court, pled guilty conditionally, and appealed the suppression ruling.

Issue	Allgier's Argument	State's Argument	Held
1. Was the traffic stop supported by reasonable suspicion that the driver was following too closely?	The 1-car-length distance alone, without known speed, was insufficient to establish reasonable suspicion.	Trooper observed very little space (~50 ft), video corroborates, and distance gave little reaction time—reasonable suspicion existed.	Stop was reasonable; trooper had reasonable suspicion to stop for following too closely.
2. Was the warrantless search of Allgier’s jacket justified by an exception to the warrant requirement?	The search was not justified by the emergency-assistance exception and violated the Fourth Amendment.	The search was reasonable under an exception (trooper sought medication/weapons to assist and protect safety).	Emergency-assistance exception did not fit, but the community-caretaker exception justified the jacket search.

Heien v. North Carolina, 135 S. Ct. 530 (U.S. 2014) (reasonable suspicion—officers allowed some mistakes of law in traffic-stop context)
Brendlin v. California, 551 U.S. 249 (U.S. 2007) (vehicle stop is a seizure of occupants)
Prado Navarette v. California, 134 S. Ct. 1683 (U.S. 2014) (reasonable-suspicion standard for traffic stops requires particularized, objective basis)
Cady v. Dombrowski, 413 U.S. 433 (U.S. 1973) (origin of community-caretaker/emergency-assistance doctrines for vehicles)
Wilson v. State, 874 P.2d 215 (Wyo. 1994) (Wyoming recognition and application of community-caretaker function)
Morris v. State, 908 P.2d 931 (Wyo. 1995) (limits on community-caretaker exception under totality of circumstances)