Permissible Scope of Traffic Stops: Vehicle Registration Inquiry and Voluntary Consent

Introduction

Richard Clark Hanson v. The State of Wyoming (2025 WY 56) presented before the Supreme Court of Wyoming on May 22, 2025, clarifies the permissible scope of a traffic stop under Article 1, § 4 of the Wyoming Constitution when an officer extends inquiry beyond initial registration and license verification. The appellant, Richard Hanson, was a passenger in a vehicle stopped for missing license plates. During the stop, Sergeant Kyle Thomson became suspicious of the vehicle’s ownership and registration validity. After a series of focused questions, he requested consent to search the car, leading to discovery of a firearm and drug paraphernalia in a backpack. Hanson was convicted of felon-in-possession of a firearm and third-offense controlled substance possession. On appeal, he challenged the stop’s duration, scope of questioning, voluntariness of consent, and the denial of sanctions for late disclosure of lab results. The Supreme Court affirmed.

Summary of the Judgment

The Court held that:

1. The extension of the traffic stop to verify lawful registration was a reasonable part of the original investigatory purpose and did not violate the Wyoming Constitution.
2. The officer’s line of questioning about vehicle ownership and the targeted question—“Anything in the car that shouldn’t be in the car?”—fell within the scope of a developing reasonable suspicion, permitting further inquiry without formal seizure extension limits.
3. Hanson’s verbal “Um, yea” consent, given amid congenial interaction and absent coercion, was voluntary under the totality-of-circumstances test.
4. The district court did not abuse its discretion in declining to suppress State Crime Lab results disclosed after the discovery deadline, as the delay arose from negligence (not bad faith), the prejudice was minimal, and Hanson declined a continuance.

Analysis

Precedents Cited

• Terry v. Ohio (392 U.S. 1): Articulates that investigative detentions must be reasonable.
• Simmons v. State (2020 WY 132): Standards for appellate review of factual findings in suppression rulings.
• Fertig v. State (2006 WY 148): Two-prong test for traffic stop reasonableness under Terry.
• Damato v. State (2003 WY 13): Driver may only proceed when licensure and registration issues are resolved.
• Harris v. State (2018 WY 14): An officer may expand detention only upon objectively reasonable articulable suspicion.
• Campbell v. State (2004 WY 106): Unrelated questioning requires reasonable suspicion of other illegal activity.
• O’Boyle v. State (2005 WY 83): On scope of traffic-stop inquiries under Article 1, § 4.
• Seymour v. State (2008 WY 61): Consent must be clear, voluntary, and not mere acquiescence.
• Naple & Requejo: Standards for sanctions due to discovery violations.

Legal Reasoning

1. Scope of the Traffic Stop: Under Article 1, § 4, a stop must be reasonable “under all the circumstances.” Following Damato and Gibson, confirming lawful registration is integral to the initial traffic-stop purpose. The Court rejected Hanson’s argument that verification of owner identity and registration must be curtailed once license and non-stolen status are confirmed. Faced with a handwritten bill of sale indicating Hanson’s name, contradictory statements by both occupants, and registration records showing a different owner, Sergeant Thomson had articulable suspicion of criminal activity—justifying continued inquiry without converting the stop into an unlawful detention.

2. Voluntariness of Consent: Applying the totality-of-circumstances test (Seymour, O’Boyle), the Court found Hanson’s consent voluntary. Officers did not coerce him; he was not under duress, told he could not refuse, nor did the questioning exceed a conversational tone. The presence of multiple uniformed officers alone does not negate voluntariness (Marinaro).

3. Discovery Sanctions: Under W.R.Cr.P. 16(d)(2) and Naple, the district court balanced the reason for delay (no bad faith), the degree of prejudice (minimal, as Hanson knew of the presumptive test result), and feasibility of cure (Hanson declined a continuance). Suppression was not proportional to the negligent oversight.

Impact

This decision reinforces that:

• Officers may lawfully extend a traffic stop to resolve registration and ownership questions essential to the stop’s purpose without triggering Fourth Amendment violation—so long as the scope remains related to the initial justification.
• Consent searches remain valid under the Wyoming Constitution when consent is given freely after reasonable, conversational questioning, even in the presence of multiple officers.
• Discovery sanctions must be calibrated to actual prejudice and the reasons behind a late disclosure; negligent delay without bad faith does not automatically warrant suppression.

Future litigants will cite Hanson to uphold vehicle searches based on extended registration inquiries and to challenge over-broad suppression requests where procedural irregularities caused only minimal prejudice.

Complex Concepts Simplified

• Investigatory Detention: A brief stop by police to confirm compliance (e.g., license, registration) that implicates Fourth Amendment protections.
• Articulable Suspicion: A specific, objective basis for suspecting criminal activity—less than probable cause but more than a mere hunch.
• Totality-of-Circumstances Test: Courts look at all factors—officer demeanor, setting, statements, presence of others—to decide if consent was truly voluntary.
• Discovery Sanctions: Remedies imposed when one side fails to share evidence timely; range from continuances to suppression or dismissal, depending on bad faith and prejudice.

Conclusion

Richard Clark Hanson v. The State of Wyoming clarifies that traffic stops may extend into thorough inquiries about vehicle registration and ownership without violating constitutional safeguards, provided officers act diligently and within a related scope. It also affirms that consent to search is evaluated by the totality of circumstances, not merely the presence of multiple officers. Finally, the case offers guidance on discovery sanctions—emphasizing proportionality and good-faith conduct. Together, these principles strengthen law enforcement’s ability to investigate legitimate concerns while preserving individual rights.