Negrete v. State

Summary

The Supreme Court of Wyoming affirmed the denial of Sotero Lepe Negrete's motion to suppress evidence obtained after a traffic stop and canine sniff of a pickup truck. The court held that the deputy's continued detention and questioning were supported by reasonable suspicion under both Article 1, § 4 of the Wyoming Constitution and the Fourth Amendment. The court concluded that the totality of circumstances justified expanding the scope of the stop.

Holdings

1. The detention was reasonable under the totality of the circumstances because the deputy had reasonable suspicion that Negrete had committed or might be committing a crime.
2. The deputy lawfully expanded the scope of the traffic-stop detention because the totality of the circumstances gave rise to reasonable suspicion of other illegal activity.

Questions Presented

1. Whether the continued detention and expansion of the traffic stop violated Article 1, § 4 of the Wyoming Constitution.
2. Whether the continued detention and expansion of the traffic stop violated the Fourth Amendment because the deputy lacked reasonable suspicion of criminal activity.

Disposition

affirmed