Clay v. State, 2016 WY 55

Summary

The Wyoming Supreme Court affirmed the denial of Marvin Clay’s motion to suppress evidence supporting his conviction for fourth-offense driving under the influence. The court held that the initial traffic stop was supported by reasonable suspicion and that the officer’s contact with Clay to investigate vehicle registration was within the scope of the stop. The officer’s subsequent observations of intoxication provided reasonable suspicion to extend the detention and investigate for DUI.

Holdings

1. The initial stop was constitutional because the officer had a particularized and objective basis to suspect that Clay was operating the vehicle without properly displayed license plates or valid temporary registration.
2. The officer's contact with Clay to investigate the title or other vehicle documentation was within the scope of the initial traffic stop and did not unlawfully expand the detention.
3. The officer developed additional reasonable suspicion of intoxication almost immediately after contacting Clay, which constitutionally permitted the detention to continue beyond the original registration investigation.

Questions Presented

1. Whether the officer's contact with Clay after the initial traffic stop improperly expanded the scope or duration of the investigative detention under the Fourth Amendment.
2. Whether the evidence supporting Clay's DUI arrest was obtained during a constitutional detention and therefore should have been suppressed.

Disposition

affirmed