Wright v. State, 440 P.3d 1092

On July 15, 2017, Officer Cleven directed traffic after a rodeo on Highway 287; he wore a helmet/vest, had cruiser lights flashing, and signaled vehicles to stop.
A pickup driven by Garrett Wright approached at highway speed, only braking rapidly and pulling to the shoulder about 30 feet past the officer after being within ~150 feet.
Cleven found Wright dazed and moving items in the vehicle; Wright delayed rolling down his window and lit a cigarette when asked to comply.
Officer Cleven smelled a strong odor of marijuana when Wright lowered the window; Wright admitted smoking marijuana earlier and that there was marijuana in the console.
Officer Cleven searched the vehicle and found marijuana and a pipe; Wright moved to suppress evidence, arguing the stop was unlawful.
The district court denied suppression (finding a traffic violation justified the stop and the odor provided probable cause for search); Wright pleaded conditional guilty and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless detention violated the Fourth Amendment and Wyoming Constitution	Wright: stop was an illegal temporary roadblock and thus unlawful detention	State: officer was lawfully directing traffic; Wright disobeyed a lawful signal, so stop was a routine traffic stop	Court: Stop was lawful — officer observed a traffic violation; detention and subsequent search justified

Whren v. United States, 517 U.S. 806 (traffic stop reasonable where officer has probable cause to believe a traffic violation occurred)
Ray v. State, 432 P.3d 872 (Wyo. 2018) (odor of marijuana alone provides probable cause to search a vehicle)
Yoeuth v. State, 206 P.3d 1278 (Wyo. 2009) (initial stop justified when officer observes traffic violation)