Miller v. State

Summary

The Supreme Court of Wyoming affirmed Jason Miller's convictions for controlled-substance offenses in two consolidated cases. The court upheld the denial of his motions to suppress, concluding that exigent circumstances justified securing his residence and that he lacked a reasonable expectation of privacy in his fiancée's vehicle. The court also held that Miller waived or failed to preserve his speedy-trial claims.

Holdings

1. The protective sweep did not violate the Fourth Amendment because officers had probable cause and exigent circumstances made it impracticable to obtain a warrant before securing the residence against possible destruction of evidence.
2. Miller failed to establish the factual nexus necessary to suppress evidence based on his allegedly unlawful detention.
3. Miller lacked a reasonable expectation of privacy in the vehicle and therefore lacked standing to challenge its search.
4. Miller's statutory and constitutional speedy-trial rights were not violated. His conditional plea waived the speedy-trial claim in docket no. 6192, and the Barker factors favored the State in docket no. 6171.

Questions Presented

1. Whether the warrantless protective sweep of Miller's residence violated the Fourth Amendment.
2. Whether Miller's detention during the protective sweep was unlawful and required suppression of the evidence obtained under the later search warrant.
3. Whether Miller had a reasonable expectation of privacy, or standing, to challenge the search of his fiancée's vehicle.
4. Whether Miller's statutory or constitutional right to a speedy trial was violated in either criminal case.

Disposition

affirmed