Rodriguez v. State, 430 P.3d 766

Troopers stopped a Buick for speeding (105 in 80); occupants: driver, front-seat passenger (Vanessa Rodriguez), and an infant. Driver gave a false name and lacked a license; Rodriguez produced a Colorado license.
Trooper Beres ran checks; dispatch flagged a protective order against a Jesse Grijalva whose description matched the driver. Trooper Kirkman (K-9) arrived as backup.
Rodriguez initially gave inconsistent statements about the driver’s identity and relationship; she later admitted the driver was Grijalva and that she had lied.
When questioned about contraband, Rodriguez admitted she had medical marijuana in a diaper bag in the back seat; a K-9 alerted and troopers recovered eight individually packaged baggies of marijuana.
Both occupants were arrested; Rodriguez moved to suppress her statements and the seized marijuana as the product of an unreasonable detention and involuntary statements. The district court denied suppression; Rodriguez entered a conditional guilty plea preserving appeal of that denial.

Issue	Rodriguez's Argument	State's Argument	Held
Whether post-stop detention/questioning exceeded the permissible scope of a traffic stop	Troopers unreasonably extended detention and questioned beyond stop scope without reasonable suspicion	Troopers developed reasonable, articulable suspicion (false identity, protective order hit, inconsistent answers) justifying continued detention and questioning	Denial of suppression affirmed — continued detention/questioning reasonable under totality of circumstances
Whether Miranda warnings were required because Rodriguez was in custody	Interrogation was custodial; statements should be suppressed for lack of Miranda warnings	Detention was non-custodial (neutral setting, short duration, no restraints, few officers); warnings not required	Not custodial; Miranda not required; statements admissible
Whether Rodriguez's statements were coerced/involuntary	Statements were coerced or elicited by improper influence, violating voluntariness and due process	Statements were voluntary; no coercive tactics (no handcuffs, no drawn weapons, short questioning)	Court found voluntariness; due process claim failed
Whether evidence seized (marijuana) should be suppressed as fruit of illegal detention/statements	Seizure was fruit of illegal detention/compelled statements; therefore inadmissible	Admission of contraband and K-9 alert provided independent justification for search/seizure	Denial of suppression affirmed; evidence admissible

Jennings v. State, 375 P.3d 788 (Wyo. 2016) (standard of review for suppression denials)
O'Boyle v. State, 117 P.3d 401 (Wyo. 2005) (traffic-stop limits: officer actions must be reasonably related to stop purpose; extension requires reasonable suspicion)
Garvin v. State, 172 P.3d 725 (Wyo. 2007) (traffic stop constitutes a seizure under the Fourth Amendment)
Flood v. State, 169 P.3d 538 (Wyo. 2007) (inconsistent statements can support reasonable suspicion to continue detention)
Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires warnings)
Berkemer v. McCarty, 468 U.S. 420 (1984) (traffic stops are normally noncustodial; custody analysis hinges on whether detention is the functional equivalent of arrest)
Perdue v. United States, 8 F.3d 1455 (10th Cir. 1993) (example of traffic-stop interrogation rising to custodial level where Miranda required)