Law School Case Brief
Wilson v. State - 874 P.2d 215 (Wyo. 1994)
Fourth Amendment guarantees require the police possess a reasonable suspicion of possible criminal behavior before a limited seizure is permitted. Reasonable suspicion requires the presence of specific and articulable facts and rational inferences on the part of the officer conducting the seizure. The Constitution does not permit any court to construct after the fact justifications of police conduct. The basic constitutional guarantee of freedom from unreasonable searches and seizures operates from a simple premise. Prior to the issuance of a warrant, the police must demonstrate probable cause. Similarly, prior to conducting an investigatory stop, the police must possess reasonable suspicions of criminal behavior. In other words, the officer's action must be justified at its inception.
Defendant was stopped in the early morning hours by a police officer acting in a community caretaker function after the officer noticed him limping while walking down a street. Following an initial offer of assistance, the officer demanded to see defendant's identification and then ran a National Crime Information Center (NCIC) and local warrants check on him. It was found out that defendant had two outstanding warrants, on the basis of which, the officer arrested defendant. Thereafter, defendant made voluntary statement implicating himself in a fire that had occurred earlier. Defendant was charged with and convicted of felony property destruction and burglary.
Was defendant's conviction proper?
The Court remanded the trial court's suppression of the evidence gathered during defendant's investigatory stop. While the Court found that the officer had acted in accord with police department policy in running the NCIC and local warrants check on defendant, the policy had resulted in an impermissible intrusion on the constitutional rights of defendant when the seizure occurred for the sole purpose of completing the warrants check. Defendant was not free to leave, and the officer lacked any reasonable suspicion of present or past criminal conduct to justify the detention. Because the seizure of defendant to complete the warrants check was illegal, the physical, tangible materials obtained either during or as a direct result of the unlawful invasion were barred from trial.
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