Michael Scott Tibbetts v. State, 2017 WY 9

Trooper Briggs stopped Michael Tibbetts for speeding after a dispatch tip about a truck possibly involved in narcotics travel. Radar showed ~76 mph in a 65 zone.
Briggs issued a citation, returned Tibbetts’ license and insurance, and told him to "drive safe and have a safe day." Briggs began to walk away.
Briggs re-approached and asked additional questions; Tibbetts produced Lortab pills and initially consented to a search, then refused; Briggs said he would detain Tibbetts until a drug dog arrived. Tibbetts then revealed meth hidden in the truck.
Tibbetts moved to suppress the statements and meth, arguing the detention was unlawfully prolonged because Briggs never told him he was free to leave and the patrol car’s emergency lights remained on.
The district court found the traffic investigation had ended, that Tibbetts was free to leave after the citation, and that the subsequent interaction was a consensual encounter; it denied suppression. Tibbetts entered a conditional no-contest plea and appealed only the suppression ruling.

Issue	Tibbetts' Argument	State's Argument	Held
Whether post‑citation contact was an unlawful continued investigatory detention	Continued detention because Briggs didn’t wait until Tibbetts actually left and lights remained flashing	Contact was consensual after citation and "drive safe"; Tibbetts was free to leave	Court held detention ended with citation and admonition; recontact was consensual
Whether overhead emergency lights alone keep a stop ongoing	Lights indicated continued seizure, so detention persisted	Lights are one factor; not dispositive when officer said free to go	Lights are a factor but do not override an unequivocal statement that the motorist is free to leave

Rodriguez v. United States, 135 S. Ct. 1609 (2015) (traffic stop cannot be prolonged for a canine sniff absent reasonable suspicion)
Ohio v. Robinette, 519 U.S. 33 (1996) (officer need not tell a seized person he is "free to go" for consent to be valid)
California v. Hodari D., 499 U.S. 621 (1991) (consensual encounter is one where a person feels free to disregard police)
Florida v. Bostick, 501 U.S. 429 (1991) (consensual encounters do not trigger Fourth Amendment seizure analysis)
McChesney v. State, 988 P.2d 1071 (Wyo. 1999) (overhead lights and vehicle blocking are strong indicators of seizure)
Marinaro v. State, 163 P.3d 833 (Wyo. 2007) (flashing lights and officer presence alone do not render consent involuntary)
Roark v. State, 103 P.3d 481 (Idaho Ct. App. 2004) (lights need not be off to end detention if officer has told motorist he is free to go)
Jennings v. State, 375 P.3d 788 (Wyo. 2016) (standard of review for suppression rulings)
Dimino v. State, 286 P.3d 739 (Wyo. 2012) (distinguishing consensual encounters from investigative detentions)