Court Summaries, 0819 WYBJ, Vol. 42 No. 5. 52

AuthorAnna Reeves Olson Park Street Law Offices Casper, Wyoming
PositionVol. 42 5 Pg. 52

Court Summaries

Vol. 42 No. 5 Pg. 52

Wyoming Bar Journal

August, 2019

Anna Reeves Olson Park Street Law Offices Casper, Wyoming

Garrett A. Wright v. State of Wyoming


2019 WY 49

May 14, 2019

In directing traffic away from the Albany County Fairgrounds at the end of a rodeo, Laramie police officer Christopher Cleven parked his patrol car in the middle of Highway 287 with lights flashing. As Cleven signaled with his flashlight for oncoming traffic to stop, an approaching pickup truck maintained highway speed until it was within 150 feet of Cleven. The truck then rapidly decreased speed and came to a stop after veering onto the right shoulder about 30 feet past Cleven. Cleven found Garrett Wright in the truck looking dazed. Rather than rolling down his window as Cleven asked, Wright lit a cigarette. When Wright finally rolled his window down, Cleven smelled a strong odor of marijuana. Eventually Wright told Cleven that he had smoked marijuana at noon that day and there was marijuana in the truck. Cleven searched the vehicle and found marijuana.

Wright moved to suppress the evidence. Following the hearing, the district court denied the motion, finding probable cause justified the initial stop. Wright entered a conditional guilty plea pursuant to W.R.Cr.P. 11(a)(2).

On appeal, Wright claimed that Cleven unlawfully detained him because he was not violating any laws, as he was traveling down the highway and was stopped pursuant to an illegal temporary roadblock. He argued that the roadblock was illegal because Cleven failed to comply with the statutory requirements set forth in Wyo. Stat. §§ 7- 17-101 through 103.

The Supreme Court disagreed with Wright and held that Cleven had not established a temporary roadblock but was merely directing traffic. The Court noted that Wyoming law authorizes law enforcement officers to direct traffic when necessary to ensure public safety. Furthermore, Wyo. Stat. § 31-5-104 states “[n]o person shall willfully fail or refuse to comply with any lawful order or direction of any police officer . . . with authority to direct, control or regulate traffic.” Here, Wright disobeyed Cleven’s signal to stop while Cleven was lawfully directing traffic. After lawfully initiating the traffic stop and asking Wright to roll down his window, Cleven smelled the strong odor of marijuana emanating from Wright’s vehicle. The odor of marijuana justified the subsequent search. The case was affirmed.

Rex Rammell v. Mountainaire Animal Clinic, P.C.; Paul Zancanella & Vicky Zancanella


2019 WY 53

May 21, 2019

Mountainaire is a veterinary clinic located in Sweetwater County. Dr. Rammell is a veterinarian and was hired by Mountainaire pursuant to an employment agreement. The agreement was for a term of one year and had a non-compete clause. After one year, Dr. Paul Zancanella, in his capacity as Mountainaire’s president, terminated Rammell’s employment.

Rammell then filed a complaint against Mountainaire and against...

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