Cristian M. Ramirez v. The State of Wyoming; Hector Zapien-Galvan v. The State of Wyoming

Summary

The Wyoming Supreme Court affirmed the denial of a joint motion to suppress more than 300 pounds of marijuana discovered during a traffic stop. The court held that the trooper’s conduct in pursuing the vehicle, including speeding to catch up, did not cause or contribute to the expired registration that justified the stop and therefore did not render the stop constitutionally unreasonable. The court also declined to consider the appellants’ racial-profiling argument because it was raised for the first time on appeal.

Holdings

1. The district court was not required to conduct a separate analysis under Article 1, § 4 because the appellants did not present a precise, analytically developed argument that the Wyoming Constitution afforded broader protection than the Fourth Amendment.
2. The traffic stop for expired registration was objectively justified and reasonable at its inception; the trooper's speeding pursuit did not invalidate the probable cause for the stop.
3. The court declined to consider the appellants' racial-profiling argument because it was raised for the first time on appeal, was unsupported by cogent argument or relevant authority, and rested on an undeveloped record.

Questions Presented

1. Whether the district court was required to conduct an independent analysis under Article 1, § 4 of the Wyoming Constitution.
2. Whether the trooper's conduct before the traffic stop was objectively unreasonable and invalidated the probable cause supporting the stop under the Wyoming Constitution or the Fourth Amendment.
3. Whether the court should consider the appellants' racial-profiling argument, raised for the first time on appeal.

Disposition

affirmed