The Wyoming Supreme Court recently issued a ruling overturning a felony DUI conviction, stating the evidence used in the trial had been unconstitutionally obtained. Samuel Snell was charged and convicted of a felony DUI after crashing his truck in July 2012. He had previously been convicted of three DUIs, so the 2012 charge was charged as a felony under state law. What would have been a fairly typical felony DUI case turned into a State Supreme Court case that could impact future DUI cases throughout Wyoming.
The case’s odd circumstances were the focal point of the Supreme Court’s decision. After the July 2012 crash, which was witnessed by a neighbor, police claimed that Snell fled the scene. Police investigated the crash, and eventually located Snell at a relative’s home. Upon finding Snell, officers observed injuries consistent with the crash the witness had described, and they also noticed the odor of alcohol. Police then administered a sobriety test, which Snell failed, and attempted to administer a breathalyzer test. Snell refused the breathalyzer test, which would have immediately revealed his blood alcohol content level. Following the refusal, officers then tried to get a warrant to draw his blood for an alcohol blood test.
This routine procedure fell off track based on what the arresting officer wrote in the warrant request, delivered on a standardized form. The officer’s affidavit requesting the warrant read: “[Snell] ran away from a traffic crash in which his vehicle rolled on a county road and ended on its side on a property not belonging to the driver. Upon contact with the driver, I detected a strong odor of an alcoholic beverage on the driver’s breath.” The warrant was granted based on the affidavit language. The blood test revealed Snell had a BAC of 0.21%, and he was later convicted of a felony DUI and sentenced to two to four years in state prison.
Snell’s attorney argued to the Supreme Court that the vague language in the warrant request made it seem as though Snell had been discovered at the scene of the accident, thus giving officers enough probable cause to think he had in fact been driving under the influence. In fact, officers had not observed Snell at the scene of the accident and had to make an assumption that he had been impaired while driving. That assumption did not translate when the officers requested the warrant. Snell’s lawyer claimed the lack of information included in the warrant request violated Snell’s constitutional rights guaranteeing protection against unreasonable search and seizure. The Supreme Court agreed, overturning Snell’s conviction.
Surprisingly, police believe the whole problem could have been avoided had the warrant request form been a little longer. The Supreme Court also observed this problem in its opinion, noting that more space on the warrant form could have prevented the vague, incomplete language that ultimately led to Snell’s conviction. Now law enforcement officials will have to rethink the format of warrant request forms to avoid little errors turning into big constitutional problems in future DUI cases.
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