Probable Cause to Search an Entire Single-Family Mobile Home Survives Franks-Omission Claims When the Suspect Has Home-Wide Access

Introduction

In Chad Everette Urrutia v. The State of Wyoming, 2026 WY 14 (Jan. 23, 2026), the Wyoming Supreme Court reviewed whether evidence of methamphetamine found in the defendant’s bedroom should have been suppressed after police obtained a second search warrant for controlled substances. The second warrant followed execution of a first warrant tied to an unrelated sexual assault investigation involving another resident, M.M., during which an officer discovered a glass pipe believed to contain methamphetamine residue.

The key issue was a classic Franks challenge based on alleged omissions: Mr. Urrutia claimed the officer’s affidavit omitted facts (including that the pipe was found in M.M.’s padlocked bedroom and that the home had multiple bedrooms and residents) and that, had those facts been included, the affidavit would not have established probable cause to search Mr. Urrutia’s bedroom.

Summary of the Opinion

The Court affirmed the denial of the motion to suppress. Even assuming the affidavit omitted the facts Mr. Urrutia identified, the Court held that supplementing the affidavit with those facts would not have defeated probable cause to search the entire single-wide residence. The Court emphasized the “nexus” requirement for probable cause and concluded that—given M.M.’s access to the home outside his locked room and Mr. Urrutia’s room being separated only by a curtain—there remained a sufficient nexus between suspected drug activity and the entire residence, including Mr. Urrutia’s bedroom.

The Court also rejected reliance on Jacobs v. City of Chicago, explaining that Jacobs concerns multi-unit buildings and does not control searches of a single-family residence such as the mobile home described in the affidavit.

Analysis

Precedents Cited

1) Probable cause framework and deference to warrants

  • Illinois v. Gates, 462 U.S. 213 (1983): The Court applied the “totality of the circumstances” approach and reiterated that an issuing judge must have a “substantial basis” for finding probable cause. Here, the presence of a suspected methamphetamine pipe in the home supported the inference that additional controlled substances could be present elsewhere in the residence.
  • Herdt v. State, 2023 WY 42, 528 P.3d 862 (Wyo. 2023): Used for both the probable cause standard and the Franks-omission framework, including the presumption of validity of warrants and sustaining “doubtful or marginal cases” in favor of the search.
  • Kreusel v. State, 2023 WY 9, 523 P.3d 312 (Wyo. 2023): Central to the Court’s analysis of probable cause as a two-part inquiry and for the “nexus” requirement linking criminal activity, items sought, and the place searched.
  • Snell v. State, 2014 WY 46, 322 P.3d 38 (Wyo. 2014), and Mathewson v. State, 2019 WY 36, 438 P.3d 189 (Wyo. 2019): Cited via Kreusel for the proposition that probable cause exists when facts would lead a reasonably prudent person to believe a crime has been or is being committed.
  • Bouch v. State, 2006 WY 122, 143 P.3d 643 (Wyo. 2006): Cited for the nexus formulation—probable cause must connect (1) criminal activity, (2) things to be seized, and (3) the place to be searched.
  • Fosen v. State, 2017 WY 82, 399 P.3d 613 (Wyo. 2017): Used to frame the inquiry as whether evidence is likely in the “area or structure sought to be searched,” supporting the Court’s focus on access within the structure and the reasonableness of searching the whole dwelling.
  • Bland v. State, 803 P.2d 856 (Wyo. 1990): Reinforced that a mobile home characterized as a single residence can be searched under a warrant supported by a sufficient affidavit establishing probable cause to search that residence.

2) Franks doctrine (misstatements and omissions)

  • Franks v. Delaware, 438 U.S. 154 (1978): The foundation for challenging a warrant based on knowing/reckless falsehoods (and, by extension, omissions). The Court restated that a defendant must ultimately show the defect was necessary to probable cause.
  • Lefferdink v. State, 2011 WY 75, 250 P.3d 173 (Wyo. 2011), and Davis v. State, 859 P.2d 89 (Wyo. 1993): Cited for Wyoming’s application of Franks, including that innocent mistakes or negligence are insufficient.
  • United States v. Garcia-Zambrano, 530 F.3d 1249 (10th Cir. 2008), and Kapinski v. City of Albuquerque, 964 F.3d 900 (10th Cir. 2020): Cited through Herdt for the two-part omission test: (1) intent/recklessness to mislead and (2) materiality—whether the supplemented affidavit would still establish probable cause.

3) Standards of review

  • Marquez v. State, 2025 WY 61, 569 P.3d 356 (Wyo. 2025), and Garcia v. State, 2025 WY 17, 563 P.3d 484 (Wyo. 2025): Used for the “clear error” standard governing factual findings, and the requirement to view evidence in the light most favorable to the district court’s determinations.
  • Kobielusz v. State, 2024 WY 10, 541 P.3d 1101 (Wyo. 2024), and Clay v. State, 2016 WY 55, 372 P.3d 195 (Wyo. 2016): Cited for de novo review of the ultimate constitutional question (the legality of the search).

4) Distinguishing multi-unit authority and discussing “locked room” limits

  • Jacobs v. City of Chicago, 215 F.3d 758 (7th Cir. 2000): The defendant argued this case required probable cause for each bedroom. The Court distinguished it as a multi-unit/apartment-block context—i.e., a doctrinal setting where “unit-by-unit” probable cause may be required.
  • Vermont v. Quigley, 892 A.2d 211 (Vt. 2005): Cited as an example where a locked bedroom can defeat extension of probable cause into that room when access is not established. The Wyoming Supreme Court used it to illustrate that Mr. Urrutia’s situation was the “opposite scenario,” because his bedroom was not secured and M.M. could access it.

Legal Reasoning

The Court treated the appeal as turning on the second (materiality) component of the omission-based Franks test: whether a hypothetical affidavit “supplemented” with the alleged omitted facts would still support probable cause. The district court had not made findings on whether the omissions were intentional or reckless, and the Supreme Court declined to reach that first prong because the materiality analysis was dispositive.

The Court then applied Wyoming’s twofold probable cause inquiry (as framed in Kreusel v. State):

  1. Crime/evidence likelihood: A suspected methamphetamine pipe with residue was found in the home during the first warrant’s execution, supporting the inference of drug possession activity in the residence.
  2. Nexus to the place searched: The affidavit (as hypothetically supplemented) would show a single-family residence with multiple occupants where M.M.’s bedroom was padlocked (limiting others’ access to it) but where M.M. could access the remainder of the trailer, including Mr. Urrutia’s bedroom separated only by a curtain. The Court found it “reasonable” that additional drugs or paraphernalia could be found elsewhere in the residence.

Critically, the Court reframed the access argument: the relevant question was not whether Mr. Urrutia could access M.M.’s locked room, but whether M.M. could access Mr. Urrutia’s area. Because the supplemented facts would tend to show M.M. had broad access (while others were blocked from M.M.’s room), the omissions did not undermine probable cause; they arguably strengthened the inference that contraband could be elsewhere in the dwelling.

Finally, the Court rejected the attempt to impose multi-unit standards on this record. The affidavit described “a single wide residence” with one mailbox and one address—facts consistent with a single-family residence, not separate living units requiring individualized probable cause.

Impact

This decision clarifies several practical points for Wyoming search-warrant litigation:

  • Materiality-first resolution of omission claims: Courts may resolve omission-based Franks challenges by deciding the “supplemented affidavit” would still establish probable cause, without addressing intent/recklessness, when that makes the intent question unnecessary to the outcome.
  • Single-family shared dwellings: In a single-family residence with multiple occupants (including a mobile home), discovery of drug evidence in one part of the home can support a warrant for the entire structure when the suspect has access across the dwelling and the affidavit supports a common-sense inference that additional contraband may be present elsewhere.
  • Locked-room limitations are fact-sensitive: A locked room may limit the scope of probable cause where access is not shown (as suggested by Vermont v. Quigley), but an unlocked or minimally separated bedroom (here, a curtain) makes it easier for probable cause to extend into that space—especially when the suspected possessor has home-wide access.
  • Multi-unit doctrine is not automatically imported: Reliance on out-of-jurisdiction multi-unit cases like Jacobs v. City of Chicago will likely fail absent facts indicating separate, unit-like living arrangements within the address searched.

Complex Concepts Simplified

  • Conditional guilty plea: A guilty plea that still preserves the right to appeal a specific ruling—here, the denial of the motion to suppress.
  • Motion to suppress: A request to exclude evidence because it was obtained in violation of constitutional protections (typically the Fourth Amendment).
  • Search-warrant affidavit: The sworn written statement of facts used to convince a judge there is probable cause to issue a warrant.
  • Probable cause: Not proof beyond a reasonable doubt; rather, a fair probability, based on common sense and the totality of the circumstances, that evidence of a crime will be found in the place to be searched.
  • Nexus: The “link” required between the suspected crime/evidence and the specific location to be searched (e.g., why drugs are likely to be found in that home or room).
  • Franks hearing: A procedure from Franks v. Delaware allowing a defendant to challenge a warrant if the affidavit contained knowing/reckless falsehoods (or, as in Wyoming, material omissions). For omissions, the key question becomes: if we add the missing facts, is there still probable cause?
  • Clear error vs. de novo: Appellate courts defer to a trial court’s factual findings unless clearly mistaken (clear error), but independently decide constitutional legality (de novo).

Conclusion

Urrutia reinforces that omission-based Franks challenges in Wyoming turn on materiality: if adding the omitted facts would not change probable cause, suppression is not warranted. In the shared-residence context, the decision underscores that probable cause to search an entire single-family dwelling (including a mobile home) remains intact when the suspected possessor has access throughout the residence—particularly where the defendant’s bedroom is not secured in a way that meaningfully limits that access.