Supreme Court: Traffic stop unlawful
CASPER — The Wyoming Supreme Court reversed the conviction of a Campbell County man who was arrested for methamphetamine and child endangerment after a traffic stop he said was unlawfully extended past its initial purpose, according to a decision last week.
William Mahaffy and his wife were pulled over in December 2019 after he dropped a lit cigarette out of a car window. Court filings say the Campbell County Sheriff’s deputy conducting the stop noticed Mahaffy’s wife was very nervous and called for a drug-sniffing dog and a handler.
After the citation had been issued, the officer asked Mahaffy, who was a passenger in the car along with his and his wife’s two children, to get out and stand by the patrol car.
“Is there a reason you guys are so nervous while I’m talking to you?” the officer asked him around a minute and a half after the citation was complete, according to transcripts included in the court’s opinion.
Court documents state the officer then began explaining the citation to Mahaffy, about 13 minutes after pulling the car over.
The dog handler reportedly nodded to indicate to the deputy that the dog had sniffed something, and a search of the car found methamphetamine and a pipe.
Mahaffy was charged with misdemeanor possession for the drug and one felony count of child endangerment since his children were in the car.
While his case was first moving through district court, Mahaffy tried to stop the evidence gathered in the last part of the traffic stop from being used in the case, but a judge denied the motion.
He pleaded guilty on the condition he would be able to seek review of that decision.
Three of the five sitting members of the Wyoming Supreme Court agreed that the traffic stop being extended past the time it took for officers to complete the citation for the lit cigarette was a violation of Mahaffy’s Fourth Amendment rights.
The amendment prohibits unreasonable searches and seizures, and precedent in Wyoming says traffic stops count as seizures of a vehicle’s occupants.
Mahaffy’s case will now be sent back to Campbell County, where it will be reviewed on remand in the lower district court where it was initially tried.
The Supreme Court’s majority opinion, written by Justice Kate Fox, cites U.S. case law that says a seizure (including a car search) from a traffic stop becomes unlawful once it’s “prolonged beyond the time reasonably required” to issue a ticket for the original violation.
Wyoming Attorney General Bridget Hill, who represented the state in the appeal, declined to comment Thursday. State Public Defender Diane Lozano, who argued on Mahaffy’s behalf, did not respond to a request for comment.
In her dissenting opinion, Justice Lynne Boomgaarden said the decision sets a wide precedent allowing anyone pulled over to contest evidence found against them during a traffic stop if the search is not directly related to the reason for the stop.