Lovato v. State, 269 P.3d 426

Detectives surveilled a house for drug activity and observed a running white Lincoln Town Car parked 3–5 feet from the curb in front of the residence.
A passenger entered the Town Car and it left; the detectives followed in an unmarked vehicle and observed traffic violations by the driver.
The passengers and driver were not initially stopped; the car abruptly stopped in the middle of the road and the passenger walked toward Detective Sekerka, then fled when confronted.
Detective Willmarth and Detective Sekerka pursued, detained the appellant after a struggle, and found methamphetamine, a digital scale, and cash on the passenger.
The appellant moved to suppress the evidence, arguing the contact was consensual and violated the Fourth Amendment; the district court denied the motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the seizure violated the Fourth Amendment.	Lovato argues the encounter was consensual and lacked probable cause.	State contends detectives had reasonable suspicion to detain and ultimately arrest Lovato.	Yes, the seizure was justified by reasonable suspicion.

Illinois v. Wardlow, 528 U.S. 119 (U.S. 2000) (flight can support reasonable suspicion for detention)
Arizona v. Johnson, 129 S. Ct. 781 (U.S. 2009) (lawful to detain vehicle occupants during vehicular inquiry)
Custer v. State, 135 P.3d 620 (Wyo. 2006) (three-tier framework for police-citizen encounters)
Feeney v. State, 208 P.3d 50 (Wyo. 2009) (two-part standard for reviewing suppression rulings; reasonable view of evidence standard)
Wardlow (consolidated with Wardlow), 528 U.S. 119 (U.S. 2000) (flight as factor in reasonable suspicion analysis)