Gabriel Augustine Tate v. State, 2016 WY 102

Defendant Gabriel Tate was arrested June 17, 2014, for a brutal sexual assault; he was Mirandized and waived rights, then interviewed by law enforcement.
About three hours after Miranda advisals and interviews, Tate was transported under a search-warrant to a hospital for a sexual-assault exam; a nurse examiner asked brief questions and Tate made incriminating voluntary statements while a police officer was present but silent.
Tate signed a hospital consent form acknowledging evidence could be used in prosecution and that he could refuse parts of the exam.
The State charged Tate; defense counsel requested a competency/fitness evaluation at arraignment, but counsel delayed filing the required written motion, producing about three months of initial delay before the evaluation order issued.
The fitness evaluation process and a few unopposed continuances accounted for much of the pretrial delay; Tate was tried July 6, 2015, convicted on most counts, and appealed contesting suppression and speedy-trial violations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of statements to nurse under Miranda	State: prior Miranda warnings and waiver were still effective; nurse followed independent medical protocols and was not a law-enforcement agent	Tate: nurse’s custodial questioning required Miranda protections and statements should be suppressed	Court: Denied suppression — prior Miranda warnings given hours earlier remained effective; change of location and short time lapse did not require re‑advisal; nurse not shown to be government agent issue unnecessary to decide
Speedy trial (W.R.Cr.P. 48 and Sixth Amendment)	State: delays largely resulted from competency proceedings and routine calendaring/unchallenged continuances; no actual prejudice to Tate	Tate: 387-day delay from arrest to conviction violated Rule 48 and Sixth Amendment speedy-trial rights	Court: Rule 48 satisfied (145 days from arraignment to trial). Under Barker balancing, delay triggered inquiry but did not warrant relief — many days attributable to defense/competency process; Tate asserted right but failed to show actual prejudice; no constitutional violation

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (established required warnings for custodial interrogations)
Dickerson v. United States, 530 U.S. 428 (U.S. 2000) (reaffirmed Miranda as constitutional rule)
Mitchell v. State, 982 P.2d 717 (Wyo. 1999) (Miranda warnings remain effective after several hours; re‑advisal not per se required)
Gunn v. State, 64 P.3d 716 (Wyo. 2003) (standard of review for suppression rulings and custodial interrogation principles)
Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (four‑factor test for Sixth Amendment speedy trial claims)
Doggett v. United States, 505 U.S. 647 (U.S. 1992) (post‑accusation delay presumptively prejudicial as it approaches one year)
Castellanos v. State, 366 P.3d 1279 (Wyo. 2016) (adoption of Barker for Wyoming constitutional speedy trial analysis)