Tiernan v. State, Department of Transportation

Summary

The Supreme Court of Wyoming reviewed an administrative suspension of William Scott Tiernan's driver's license after he refused chemical testing following a suspected impaired-driving stop. The court held that the trooper's report and patrol-car DVD provided substantial evidence and probable cause to stop Tiernan for failing to maintain a single lane of traffic. The court affirmed the district court's decision upholding the Office of Administrative Hearings' suspension order.

Holdings

1. A law-enforcement officer's personal observation of a traffic-law violation provides probable cause to initiate a traffic stop. Reasonable suspicion remains the applicable standard when the officer did not personally observe a traffic violation and relies on the totality of the circumstances.
2. The agency's decision was supported by substantial evidence because the trooper's report described repeated lane deviations and the DVD, although unclear as to actual crossings, corroborated repeated drifting from one side of the lane to the other.

Questions Presented

1. Whether the patrol-car DVD and the trooper's report supported a finding that the trooper had probable cause to stop Tiernan for failing to maintain a single lane of traffic in violation of Wyo. Stat. Ann. § 31-5-209(a)(i).
2. Whether the agency's decision upholding the implied-consent driver's-license suspension was supported by substantial evidence.

Disposition

affirmed