Gregory Matthews v. The State of Wyoming
2014 WY 54
| Wyo. | 2014Background
- On Nov. 20–21, 2011, Jackson officers investigated a fight; officers believed Matthews had driven from the scene while intoxicated and arrested him for DWUI after he refused a chemical test.
- Officer Ayling obtained a warrant for a blood draw; at the jail Ayling asked Matthews to comply and Matthews said “no,” leading to a charge of interference with a peace officer under Wyo. Stat. § 6-5-204(a).
- Matthews filed pretrial motions: to suppress statements, to dismiss charges (arguing a verbal “no” is not interference), and to dismiss for lack of probable cause; the circuit court denied those motions, finding the dismissal issue not susceptible to Rule 12(b) pretrial resolution.
- Matthews entered a conditional guilty plea to the interference charge, with the State’s consent and the trial court’s oral approval, reserving in writing the right to appeal the denials of his Feb. 7 & 8, 2012 pretrial orders.
- The district court affirmed the circuit court on several points (probable-cause appeal barred, verbal refusal constituted interference, implied-consent advisement lawful, suppression denial proper). The Wyoming Supreme Court granted review and reversed and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of the conditional guilty plea under W.R.Cr.P. 11(a)(2) | Matthews argued his written reservation of the right to appeal pretrial denials made the conditional plea proper. | State argued it consented and the plea was approved, so the conditional plea should be enforced. | Court held the plea was invalid because one reserved issue (motion to dismiss for lack of probable cause) was not a pretrial issue under Rule 12(b), so conditional-plea protection did not apply; Matthews may withdraw plea. |
| Whether denial of motion to dismiss for lack of probable cause was reviewable in the conditional plea | Matthews argued the denial should be reviewable on appeal via the conditional plea. | State argued the issue was not a proper pretrial motion and thus not reviewable in a conditional plea. | Court held the motion to dismiss implicated the general issue for trial (whether conduct constituted interference) and was not a Rule 12(b) pretrial matter; therefore not reviewable in a conditional plea. |
| Whether Matthews’ verbal refusal constituted interference with a peace officer | Matthews contended a verbal “no” to comply with the warrant is insufficient to constitute interference as a matter suitable for pretrial resolution. | State maintained the refusal supported an interference charge and the denial of dismissal was correct. | Court observed on the record that a full trial development is required to determine whether the refusal constituted interference; it did not resolve the substantive question on the plea-appeal. |
| Lawfulness of the implied-consent advisement and suppression ruling | Matthews argued the advisement was false/misleading and suppression should have been granted; also argued Miranda interrogation issues. | State argued the advisement was lawful and Miranda did not apply because asking whether he would comply was not interrogation. | District court had held the advisement lawful and suppression denial proper; the Supreme Court did not reach final resolution because it disposed of the case on the invalidity of the conditional plea, leaving factual/merits questions for trial or further proceedings. |
Key Cases Cited
- Walters v. State, 197 P.3d 1273 (Wyo. 2008) (defines requirements and limits for conditional guilty pleas)
- Lefkowitz v. Newsome, 420 U.S. 283 (1975) (upholding conditional plea procedure as easing calendar congestion without sacrificing appellate rights)
- United States v. Yager, 756 F.2d 1058 (5th Cir. 1985) (entrapment and similar defenses are not susceptible to pretrial resolution for conditional-plea appeals)
- Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda interrogation/advisement principles)