327 P.3d 114
Wyo.2014Background
- Engdahl entered a conditional Alford plea to one count of possession of a controlled substance, conditioned on appeal of the district court’s suppression ruling.
- Deputy stopped a pickup for missing license plates; driver Harris and passenger Engdahl identified themselves.
- Deputy learned both had prior drug histories; Harris’s license was suspended; deputy planned citation for driving on a suspended license.
- Engdahl asked to leave; deputy told her to hang out for a sec while he confirmed truck ownership via VIN; Corporal Parker arrived.
- Dog sniff occurred during the stop; dog indicated drugs in the vehicle; Engdahl handed over a methamphetamine pipe and placed two baggies on the hood at deputy’s request.
- Deputies searched Engdahl’s coat and found a large chunk of meth; she was arrested; suppression motion denied by district court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was reasonable suspicion to detain Engdahl beyond the stop. | Engdahl argues the detainment violated the Terry framework and Miranda rights should have been read. | State contends the detention remained within the scope of the initial stop and was supported by articulable suspicion. | No reversible error; detention reasonable and Miranda not required. |
Key Cases Cited
- Damato v. State, 64 P.3d 700 (Wyoming 2003) (two-part Terry framework for traffic stops)
- Garvin v. State, 172 P.3d 725 (Wyoming 2007) (guides on stop and on-scene detention scope)
- Damato v. State, 64 P.3d 700 (Wyoming 2003) (evidence of reasonable suspicion and scope of detention)
- Jelle v. State, 119 P.3d 403 (Wyoming 2005) (custodial interrogation factors and on-scene questioning)
- Nava v. State, 228 P.3d 1311 (Wyoming 2010) (objective reasonable-man standard for custody; totality of circumstances)
- Lovato v. State, 269 P.3d 426 (Wyoming 2012) (detention during traffic stop and canine sniff admissibility)