Public-domain · open source
OpenJurist

2006 WY 120

Rohda v. State

Wyoming Supreme Court

Decided September 27, 2006

Wyoming Supreme Court · decided 2006-09-27

Key passage — most relied on by later courts

“The duty of reviewing courts is simply to ensure that the warrant-issuing judicial officer had a substantial basis for concluding that probable cause existed. As both our Court and the United States Supreme Court have recognized, the resolution of doubtful or marginal cases in this area should be largely determined by the preference to be accorded to warrants.”

quoted by 1 later decision, including Abeyta v. State

Relies on United States v. Sims · United States v. Tuter · United States v. Soderstrand

Good law ✅— No negative treatment on recordhow we know

Decided 2006-09-27

How this case has been cited

Cited by 17 later decisions — most recently July 2024

17 state decisions

90200620102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

VOIGT, Chief Justice,

¶1specially concurring.

¶2[¶ 28] I concur. I write separately only because, as was pointed out in In re TJS v. State, 2005 WY 68, ¶ 9 n. 1, 113 P.3d 1054, 1057 n. 1 (Wyo.2005), our case law concerning the standard for reviewing probable cause determinations in the search warrant context is inconsistent, and I do not believe we should continue to cite the cases that reflect that inconsistency. In juxtaposing the two standards — de novo review and deferential review — in Cordova v. State, 2001 WY 96, ¶¶ 10-11, 33 P.3d 142, 147-48 (Wyo.2001), we very nearly recognized their incompatibility, but in the end, blessed them both. But, “de novo with deference” just does not make sense. In fact, the two concepts are polar opposites.

¶3[¶ 29] I believe it is time to say directly that “deference,” as defined by the federal cases, is the appropriate standard of review under either constitution, and that we are not applying de novo review of search warrant affidavits for probable cause, contrary to what we said in In re TJS. See United States v. Sims, 428 F.3d 945, 954 (10th Cir.2005); United States v. Soderstrand, 412 F.3d 1146, 1152-53 (10th Cir.2005), cert. denied, — U.S. -, 126 S.Ct. 1478, 164 L.Ed.2d 249 (2006); United States v. Tuter, 240 F.3d 1292, 1295 (10th Cir.2001); and 6 Wayne R. LaFave, Search and Seizure § 11.7(c), at 451-56 (4th ed. 2004) (Supp.2006). Our intent, as we apply these constitutional provisions, is to give guidance to law enforcement officers and issuing magistrates. That goal is best served by establishing and sticking to the standard of review the majority espouses sub silentio today: The duty of reviewing courts is simply to ensure that the warrant-issuing judicial officer had a substantial basis for concluding that probable cause existed. It goes without saying, of course, that such substantial basis must have been contained within the four corners of the affidavit presented with the requested warrant.

/2006/wy/120 · .json · Public domain