Colyer v. State, Department of Transportation

Summary

The Wyoming Supreme Court affirmed the suspension of David R. Colyer's driver's license after he refused chemical testing following a DUI arrest. The court held that his detention by a Bureau of Indian Affairs officer on the Wind River Indian Reservation did not render his subsequent arrest by a Fremont County deputy sheriff unlawful.

Holdings

1. A B.I.A. officer's detention of a non-Indian driver on an Indian reservation pending formal arrest by a state officer does not render the subsequent state arrest unlawful when the state officer lawfully arrests the driver within state jurisdiction.
2. The State proved by a preponderance of the evidence the statutory elements required to suspend Colyer's driver's license for refusing a chemical test after a lawful driving-under-the-influence arrest.

Questions Presented

1. Whether detention of a non-Indian driver by a Bureau of Indian Affairs officer on the Wind River Indian Reservation rendered unlawful the subsequent otherwise lawful arrest by a Fremont County deputy sheriff.
2. Whether the driver's license suspension was supported by the statutory elements governing refusal of chemical testing after a lawful driving-under-the-influence arrest.

Disposition

affirmed