Wilson v. State
874 P.2d 215, 1994 Wyo. LEXIS 48, 1994 WL 131227 (1994)
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Rule of Law:
Detaining a citizen for the sole purpose of completing a warrants check constitutes a seizure under the Fourth Amendment, which is unreasonable and unconstitutional unless supported by a reasonable, articulable suspicion of past or present criminal activity.
Facts:
- At 12:31 a.m., Officer Kamron Ritter of the Casper Police Department saw Wesley Wilson walking with a severe limp.
- Concerned for his safety, Officer Ritter stopped and asked Wilson what was wrong; Wilson replied that he had twisted his ankle at a party.
- Officer Ritter smelled alcohol on Wilson's breath, requested his identification, and radioed for a routine warrants check.
- A fire was reported nearby, and before leaving to investigate, Officer Ritter told Wilson to 'stay in the area.'
- Wilson did not stay in the immediate area, instead limping about 40 feet farther down the street.
- After about eight minutes, Officer Ritter returned, helped Wilson cross the street to avoid approaching fire trucks, and then instructed him to go to a specific street corner and 'wait.'
- Wilson complied with the officer's instruction and sat on a lawn at the designated corner to wait.
- While Wilson was waiting as instructed, the police dispatcher radioed that Wilson had two outstanding arrest warrants.
Procedural Posture:
- Wilson was charged with felony property destruction and burglary in the district court.
- Wilson filed a pretrial motion to suppress evidence, arguing the stop and his subsequent detention were illegal.
- The district court denied the motion to suppress, ruling that the officer's actions were entirely reasonable.
- Following a trial, a jury convicted Wilson on both counts.
- Wilson appealed his conviction to the Wyoming Supreme Court, which is the state's highest court.
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Issue:
Does a police officer's detention of a citizen, solely to complete a warrants check without any reasonable suspicion of criminal activity, constitute an unreasonable seizure in violation of the Fourth Amendment?
Opinions:
Majority - Taylor, Justice.
Yes. Detaining a citizen solely to complete a warrants check without reasonable suspicion of criminal activity is an unreasonable seizure that violates the Fourth Amendment. The initially consensual encounter transformed into a seizure when Officer Ritter instructed Wilson to go to a specific corner and wait, and Wilson submitted to this show of authority. A reasonable person in that situation would not have felt free to leave. This seizure was not justified at its inception because, by the officer's own admission, he lacked any reasonable suspicion that Wilson was involved in any past or present criminal conduct. While police may conduct a warrants check during a lawful traffic stop based on a violation, they cannot seize a pedestrian for that purpose without independent, articulable suspicion of a crime. Because the seizure was unconstitutional from its inception, the evidence obtained as a direct result must be suppressed under the exclusionary rule.
Dissenting - Thomas, Justice.
No. The officer's conduct was reasonable under the circumstances, and no seizure occurred prior to Wilson's lawful arrest on the outstanding warrants. The trial court's finding that the encounter was reasonable was not clearly erroneous and should have been upheld. The entire interaction was a consensual, first-tier encounter where Wilson voluntarily cooperated. The officer's instruction to wait was given in the context of an emergency fire situation and a brief, ten-minute period. A reasonable person would still have felt free to leave, and the majority improperly substitutes its own subjective judgment for the objective facts and the trial court's findings.
Dissenting - Cardine, Justice.
No. The officer asking Wilson to wait for what turned out to be ten minutes was not an unlawful seizure. The initial encounter was lawful, and the officer was concurrently managing an active arson investigation and directing traffic. Requesting a person at the scene of a potential crime to wait briefly while awaiting an NCIC report is an accepted and reasonable law enforcement activity, not a violation of constitutional guarantees. Therefore, the trial court's denial of the motion to suppress should have been affirmed.
Analysis:
This decision reinforces the distinction between a consensual police-citizen encounter and an investigatory detention (a 'seizure') that implicates the Fourth Amendment. It clarifies that an officer's 'community caretaking' function does not create a blanket authority to detain individuals for administrative checks. The ruling establishes that a seizure for the purpose of a warrants check, like any other Terry stop, requires its own independent justification in the form of reasonable suspicion at its inception. This precedent curtails police authority to detain citizens based on department policy or a hunch, requiring specific, articulable facts of criminal activity before restricting a person's liberty, even temporarily.
