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Wyoming Supreme Court Reverses ‘Contempt of Cop’ Conviction Because Police Were Not Lawfully Performing Their Official Duties

by Richard Resch

The Supreme Court of Wyoming ­reversed Myron Martize Woods’ conviction for interference with a peace officer because the arresting officers’ warrantless entry into his home, without any applicable exception, meant that they were acting unlawfully in effectuating his arrest, but an “elemental” requirement of this offense is that the police were lawfully performing their official duties. 

On February 13, 2020, Cheyenne Police Department Officer Warren was called to the home of Brittany Jackson for a domestic disturbance. Jackson claimed that Woods grabbed her neck and pushed her. Warren did not see any marks on Jackson’s neck, so he concluded that there was not probable cause to arrest Woods.

Approximately two hours later, Warrant and his supervisor, Sergeant Young, returned to Jackson’s home in response to her request for further investigation. This time, the officers observed marks on her neck and determined that there was probable cause to arrest Woods for misdemeanor domestic battery. Mistakenly believing that an arrest warrant was not required under Wyo. Stat. Ann. § 7-20-102(a) because the alleged offense occurred less than 24 hours ago, the officers did not attempt to obtain an arrest warrant for Woods.

Warren, Young, and a third officer arrived at Wood’s residence about an hour later to arrest him. They knocked on the front door, and Woods’ girlfriend, Evelyn Rodriguez, answered the door and stood at the threshold of the residence with Woods behind her. The officers asked him to step outside to talk about what happened at Jackson’s home, but Woods repeatedly refused, stating that nothing happened.

Eventually, Warren breached the threshold to grab Woods’ wrist and drag him outside, but Woods broke free. At that point, the officers pushed past Rodriguez to physically subdue Woods and place him under arrest.

The State charged him with domestic battery and interference with a peace officer. Woods filed a suppression motion, challenging his warrantless arrest in his home and seeking all evidence related to the arrest suppressed as a violation of his Fourth Amendment rights. The trial court denied the motion, and he was acquitted of domestic battery but convicted of interference with a peace officer under Wyo. Stat. Ann. § 6-5-204(a). The court sentenced him to 365 days in jail. Woods appealed, and the appellate court affirmed. He timely appealed to the state Supreme Court.

The Court framed the dispositive issue as: “Whether the officers arrested Mr. Woods while engaged in the lawful performance of their official duties as required to convict him” under the statute. It answered this question in the negative.

The Court began its analysis with the axiom that the lawfulness of a defendant’s arrest is “elemental” to the offense of interference with a peace officer because interference “is not a crime unless the officer is ‘engaged in the lawful performance of his official duties.” Mickelson v. State, 906 P.2d 1020 (Wyo. 1995) (quoting Wyo. Stat. Ann. § 6-5-204(a) and (b)). Whether an officer is lawfully performing official duties is a question of law that the Supreme Court reviews de novo. Id.

The Court turned to the Fourth Amendment in its analysis, noting that the U.S. Supreme Court (“SCOTUS”) has advised that “physical entry of the home is the chief evil against which the wording of the Fourth Amendment is directed.” Payton v. New York, 445 U.S. 573 (1980). SCOTUS draws “a firm line at the entrance to the house.” Lange v. California, 141 S. Ct. 2011 (2021). Additionally, SCOTUS has cautioned that any “physical invasion of the structure of the home, ‘by even a fraction of an inch,’ [is] too much….” Kyllo v. United States, 533 U.S. 27 (2001). Consequently, the general rule is that the Fourth Amendment requires the police to obtain a warrant prior to entering a person’s home without consent. Lange

The Court added that the state Supreme Court has similarly recognized “the important role of the Fourth Amendment in relation to the home.” Hawken v. State, 511 P.3d 176 (Wyo. 2022). It noted that the State has the burden of establishing that an exception to the warrant requirement for entering a home applies such as consent, exigent circumstances, hot pursuit of a fleeing suspect among others. Fenton v. State, 154 P.3d 974 (Wyo. 2007); Vassar v. State, 99 P.3d 987 (Wyo. 2004). 

Turning to the present case, Warren acknowledged at trial that at the time of arrest, he did not suspect: (1) Woods possessed any weapons, (2) he posed an imminent threat to Jackson, (3) he possessed any evidence in danger of being destroyed, and (4) there were any extenuating circumstances necessitating his immediate arrest. See Lange (when no exigency exists, “officers must respect the sanctity of the home – which means that they must get a warrant.”).

The Court determined that the officers’ warrantless entry into Woods’ home was per se unreasonable and that the State has failed to prove that an exception to the warrant requirement applied. It further determined that the officers’ warrantless entry into Woods’ home to effectuate his arrest violated his Fourth Amendment rights. As a result, the officers were not engaged in the lawful discharge of their official duties when they arrested Woods, according to the Court. Thus, the Court held that his “conviction for misdemeanor interference with a peace officer cannot stand.”

Accordingly, the Court reversed the decision of the appellate court. See: Woods v. State, 527 P.3d 264 (Wyo. 2023).   

 

 

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