Chace v. The State of Wyoming
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The case revolves around the defendant, Daniel A. Chace, who appealed the denial of his motion to suppress evidence obtained through a search warrant executed after 10:00 p.m. The incident began when law enforcement stopped a vehicle for a traffic violation, driven by Mr. Chace’s brother. A search of the vehicle following a K-9 unit’s drug alert resulted in the discovery of methamphetamine and paraphernalia. That evening, the officers requested a search warrant for the driver's residence, where Mr. Chace was temporarily staying. The search warrant was executed shortly after 10:00 p.m., leading to the discovery of more drugs and paraphernalia in Mr. Chace's backpack.
Mr. Chace argued that the evidence should be suppressed because the search of the residence violated Rule 41 of Wyoming's Rules of Criminal Procedure, which restricts the execution of search warrants to between 6:00 a.m. and 10:00 p.m., unless express authorization for a different time is provided based on good cause. The Supreme Court of Wyoming, however, affirmed the district court's decision, concluding that the nighttime search did not prejudice Mr. Chace and that law enforcement did not intentionally and deliberately disregard the limits in Rule 41(e)(1). The court maintained that a violation of Rule 41 alone does not necessarily equate to a Fourth Amendment violation and does not always invoke the application of the exclusionary rule.
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