Samuel P. Snell v. The State of Wyoming
2014 WY 46
| Wyo. | 2014Background
- Around July 7, 2012, a pickup rolled over on a rural road; a witness saw someone flee from the vehicle but could not identify them at distance.
- Deputies checked registration, contacted the registered owner (Appellant’s mother), and began a search; about two hours after the crash deputies located Samuel P. Snell about 1/10 mile from the residence.
- Deputy Gibson observed signs of intoxication (strong odor of alcohol, slurred speech), injuries and torn clothing, and Snell performed poorly on field sobriety tests; Snell initially denied driving and refused a breath test at the jail.
- Deputy Gibson obtained a search warrant (using a short form affidavit) authorizing blood, breath and/or urine; blood was drawn about four hours after the crash and showed BAC 0.21%.
- Snell moved to suppress the BAC test, arguing the warrant affidavit was conclusory and lacked probable cause/nexus that he had been the driver; the district court denied suppression, and a jury convicted Snell of felony DWUI (fourth-or-subsequent).
- The Wyoming Supreme Court reviewed the warrant affidavit de novo and reversed suppression denial, holding the affidavit contained bare conclusions and failed to supply underlying facts establishing that Snell was the driver (and thus failed to establish the necessary nexus).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of affidavit for warrant to draw blood | Snell: affidavit was conclusory and omitted facts showing how officer linked Snell to driving the vehicle; therefore no probable cause/nexus | State: affidavit and circumstances supported probable cause to believe Snell was driver and blood would contain evidence | Court: affidavit lacked underlying factual detail showing nexus between crime and person; suppression required (warrant deficient) |
| Applicability of Leon good-faith exception | Snell: suppression necessary despite any officer reliance on warrant | State: even if affidavit defective, evidence admissible under good-faith reliance on warrant | Court: declined to decide/apply Leon because issue not developed below and no testimony showing officer’s good-faith reliance; reserved question for another day |
Key Cases Cited
- Bouch v. State, 143 P.3d 643 (Wyo. 2006) (affidavit must include more than bare conclusions; nexus requirement)
- TJS v. State, 113 P.3d 1054 (Wyo. 2005) (de novo review of affidavit and requirement that factual support appear within affidavit)
- Schirber v. State, 142 P.3d 1169 (Wyo. 2006) (some underlying factual information required; affidavit cannot be mere suspicion)
- Lefferdink v. State, 250 P.3d 173 (Wyo. 2011) (totality-of-circumstances test for probable cause in warrant affidavits)
- United States v. Leon, 468 U.S. 897 (U.S. 1984) (good-faith exception to exclusionary rule; discussed but not applied)