Benjamin Q. McChesney, Appellant (defendant) v. the State of Wyoming, Appellee (plaintiff)

Summary

The Wyoming Supreme Court reversed the denial of McChesney's motion to suppress, holding that an anonymous REDDI tip of erratic driving—corroborated only by an officer's location of a matching vehicle driven without any observed violation—did not create reasonable suspicion for an investigatory stop. The court first concluded that activating the patrol car's emergency lights and parking behind McChesney's blocked vehicle effected a Fourth Amendment seizure, rejecting the State's consensual-encounter argument; because neither the low-reliability anonymous tip nor the officer's observations of innocent conduct supplied specific and articulable facts, the seizure was unlawful, the evidence had to be suppressed, and McChesney may withdraw his conditional guilty plea on remand. Justice Thomas, dissenting, joined by District Judge Kalokathis, would have affirmed, reasoning that corroboration of the person, vehicle, and location described—weighed against the public-safety danger posed by a possibly impaired driver—sufficed under the totality of the circumstances.