Caleb Aaron Campbell v. State of Wyoming

Summary

The Wyoming Supreme Court reviewed the denial of Caleb Campbell’s motion to suppress evidence after his conditional guilty plea to felony possession of marijuana. The court held that police officers’ initial warrantless entry into Campbell’s apartment was not justified by the emergency assistance exception, but agreed that Campbell’s later consent was voluntary. The case was remanded for the district court to determine whether that consent was tainted by the initial unlawful entry.

Holdings

1. The emergency assistance exception did not justify the initial entry because the officers lacked a reasonable and articulable belief that a genuine emergency requiring immediate assistance existed.
2. Campbell's consent to the later entry and searches was voluntary and was not the result of police coercion.
3. Voluntary consent alone does not purge the taint of a prior unlawful search; the State must also establish that the consent was sufficiently separated from the illegality and was not obtained by exploiting it. The record was insufficient for the Supreme Court to decide that question, requiring remand.

Questions Presented

1. Whether the officers' initial warrantless entry into Campbell's apartment was justified by the emergency assistance exception to the Fourth Amendment's warrant requirement.
2. Whether Campbell voluntarily consented to the officers' later entry and searches of the apartment.
3. Whether, even if Campbell's consent was voluntary, the initial unlawful entry tainted the later consent and the evidence discovered through the consensual searches.

Disposition

remanded