Background
In December 2024, Uinta County Sheriff’s Deputy Kerby Barker investigated an abandoned stolen U-Haul truck at Narrows Reservoir near Evanston, Wyoming. The truck, bearing Arizona registration, had been rented by a third party under the name Demetric Matlock and never returned. While examining the scene, Deputy Barker reviewed three receipts found in the cab and watched surveillance video provided by Evanston Police Officer Zach Marler—video showing a U-Haul with the same distinctive side graphics parked outside a residence at 133 2nd Avenue, recently rented by Christopher and Amanda Campbell, who had moved from Arizona. Jesse Padilla, whose identity was linked to the receipts, was known to stay frequently at the Campbells’ home. Both Campbells had criminal histories involving theft, forgery, and auto burglary; a Toyota Tundra registered to Amanda Campbell in Arizona was parked at the residence; and its tires appeared to match tracks at the abandoned truck’s location.
Based on these facts, Deputy Barker obtained a search warrant for 133 2nd Avenue. Executing the first warrant, officers found marijuana and heroin in plain view alongside guns and ammunition, then applied for a second warrant. The second search uncovered methamphetamine, fentanyl, heroin, burglary tools, forgery devices, and a motorcycle with its VIN scratched off. The State charged Campbell with twelve counts. He entered conditional pleas to six—theft, three counts of possession with intent to deliver, possession of forgery devices, and possession of burglar’s tools—reserving his right to challenge the denial of his suppression motion. The district court had held the affidavit sufficient; the Wyoming Supreme Court, which hears criminal appeals directly from district court (Wyoming has no intermediate court of appeals), took up the challenge.
The Court’s Holding
Affirmed. Writing for a unanimous five-justice panel, Justice Fenn held that Deputy Barker’s affidavit, evaluated under the totality-of-circumstances standard, established probable cause to search the Campbells’ residence. The court applied de novo review.
The court reaffirmed the two-prong framework for probable cause under both the Fourth Amendment and Article 1, § 4 of the Wyoming Constitution—which independently requires affidavit support for every search warrant issued in Wyoming. The first prong (facts showing a crime was committed) was conceded by Campbell. On the nexus prong—whether evidence was likely to be found at the named location—the court rejected his paragraph-by-paragraph challenge as methodologically unsound. The totality-of-circumstances test requires courts to evaluate all material evidence together, not in piecemeal fashion. Rohda v. State, 2006 WY 120, ¶ 11, 142 P.3d 1155, 1164 (Wyo. 2006). The standard demands a practical, common-sense judgment whether “there is a fair probability that contraband or evidence of a crime will be found in a particular place.” Illinois v. Gates, 462 U.S. 213, 238 (1983).
Viewed in its totality, the affidavit wove multiple circumstantial strands into a coherent picture: the stolen U-Haul had been seen parked at the Campbells’ residence; receipts linked Padilla to the truck, and Padilla was a frequent occupant at that address; the Campbells had recently relocated from Arizona, the U-Haul’s state of origin; tire tracks at the scene appeared to match Amanda Campbell’s vehicle; and both Campbells had criminal records for precisely the offenses under investigation. The court also confirmed that information provided by fellow law enforcement officers—including those from other agencies or jurisdictions—carries a presumption of truthfulness and reliability, eliminating any need to separately establish the secondary source’s credibility. Rohda, ¶ 8, 142 P.3d at 1159–60. Because the first warrant was valid, the second warrant and all evidence derived from it survived as well.
Key Takeaways
- Wyoming courts review search-warrant affidavits de novo, applying the totality-of-circumstances standard. Probable cause must be assessed from the affidavit as a whole—a paragraph-by-paragraph deconstruction asking whether each sentence independently establishes nexus or source credibility is an improper analytical framework and will not succeed on appeal.
- Article 1, § 4 of the Wyoming Constitution independently requires affidavit support for every search warrant, grounding Wyoming’s probable-cause analysis in state law as well as the federal Fourth Amendment. Practitioners should cite both provisions to preserve independent state-law grounds for suppression.
- Information provided by law enforcement officers—whether from the same agency, another Wyoming agency, or an out-of-state department—is presumed truthful and reliable in a warrant affidavit. No special corroboration of the secondary source’s credibility is required.
- A successful challenge to an initial search warrant automatically taints all evidence discovered under a subsequent warrant as “fruit of the poisonous tree.” Conversely, where the first warrant is upheld, the second warrant and its evidence stand with it.
Why It Matters
For Wyoming criminal defense practitioners, Campbell confirms that suppression arguments built by isolating individual sentences of a warrant affidavit are unlikely to gain traction. Wyoming courts begin with a presumption of validity and synthesize all the facts rather than silo them. The more viable defense path—particularly where the affidavit rests on inferential chains rather than direct evidence of presence at the search location—is to argue that the cumulative picture, even under a generous totality-of-circumstances reading, still falls short of a fair probability of finding evidence. That argument remained available to Campbell but failed on these facts given the density of Arizona-linked connections between the stolen truck and the Campbells’ home.
The decision also illustrates the practical weight of Wyoming’s direct-appeal structure. Because the Wyoming Supreme Court is the first and only appellate court for criminal suppression rulings, each opinion it issues on Fourth Amendment doctrine becomes binding law immediately, with no intermediate court to develop or cabin the rule first. Defense counsel and prosecutors handling suppression issues in Wyoming should treat Supreme Court warrant decisions as high-priority reading, since they define the controlling standard without any buffering layer of intermediate review.