Constitutional Cases
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Constitutional

Wyoming Supreme Court
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Campbell v. State — Totality of Circumstances, Not Paragraph-by-Paragraph Scrutiny, Controls Probable Cause Review

The Wyoming Supreme Court unanimously affirmed the denial of Christopher Campbell’s motion to suppress evidence seized from his Evanston residence, holding that Deputy Barker’s search-warrant affidavit established probable cause under the totality-of-circumstances test. The court rejected Campbell’s paragraph-by-paragraph critique of the affidavit as methodologically improper: Wyoming law requires courts to evaluate the affidavit as a whole, not in piecemeal fashion. Viewed in its totality, a convergence of circumstantial links—a matching U-Haul seen at the residence, receipts tying an associate to both the truck and the address, Arizona connections shared by the stolen vehicle and the occupants, and matching tire tracks—established the required nexus between the evidence sought and the place to be searched.

Court of Appeals of Alaska
Uncategorized

Frankson v. State — State Breaches Plea Agreement When Successor Prosecutor Argues Against Agreed Sentence on Remand; Sentence Vacated for Failure to Obtain Defendant’s Personal Plea Reaffirmation

The Alaska Court of Appeals vacated Nick Frankson’s assault sentences on two grounds: the successor prosecutor breached the plea agreement by actively arguing against the parties’ agreed 720-day sentence on remand, and the superior court failed to personally address Frankson before proceeding to open sentencing after rejecting the sentencing agreement under Alaska Criminal Rule 11(e)(3). The court separately held that using Frankson’s nine prior assault convictions to find AS 12.55.155(c)(8) did not violate the Sixth Amendment under Erlinger v. United States, because determining that multiple dated assault convictions constitute ‘repeated instances of assaultive behavior’ requires examining only the bare conviction record — not the fact-laden inquiry that Erlinger held must go to a jury.

Court of Appeals of Utah
Uncategorized

State v. Saunders — Plain View Probable Cause Survives Absent Body Camera and Negative Field Tests

The Utah Court of Appeals affirmed the denial of a motion to suppress evidence seized in plain view during a traffic stop, holding that an officer’s probable cause determination was reasonable under the totality of the circumstances even though the detective’s body camera was not recording and subsequent field tests on the seized baggie returned negative or inconclusive results.

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