Court tosses man’s conviction

CASPER — The Wyoming Supreme Court on Monday reversed the conviction of a Cheyenne man who successfully argued officers’ warrantless entry into his home violated his rights. 
 
Myron Martize Woods’ conviction came after Cheyenne police entered his home without a warrant to arrest him for misdemeanor domestic battery. But, the high court concluded, the circumstances did not exist that would have legally permitted officers to do so without a warrant. 
 
On Feb. 13, 2020, the Cheyenne Police Department received a report of a disturbance. 
 
Officers found Woods, his wife and his ex-girlfriend at the scene. 
 
Woods and his ex-girlfriend share a son. The two had been arguing that evening after the ex-girlfriend saw Woods at Walmart without their son, whom he was supposed to be watching. He was accused of grabbing her neck and pushing her while she was trying to get their son out of his car. 
 
After an officer interviewed all of the involved parties, he found there was not enough cause to arrest Woods, the ruling states. 
 
The ex-girlfriend called police later that night after marks on her neck began appearing, the ruling states. The officer believed he now had enough evidence to arrest Woods for misdemeanor domestic battery. 
 
But the officer did not try to obtain an arrest warrant, believing it was not required within 24 hours of the alleged offense, the ruling states. 
 
Just before midnight, three officers arrived at Woods’ home. A body camera on one of the officers captured the interaction. Woods’ wife answered the door, and he was standing directly behind her. The officers repeatedly questioned Woods about what happened and asked him to step out of his home. He declined. 
 
An officer eventually reached over the threshold of the home to grab Woods’ wrist and pull him outside, the ruling states. Police struggled with him for over two minutes before handcuffing him and forcing him out of his house. 
 
The state charged Woods with one count of misdemeanor domestic battery and one count of interference with a peace officer. 
 
Woods filed a motion to suppress the evidence, which he argued was obtained in violation of his Fourth Amendment right. The court denied his motion. 
 
In April 2021, Woods was acquitted of domestic battery but found guilty of police interference during a jury trial held in Laramie County Circuit Court. He was sentenced to one year of probation. 
Woods appealed his conviction in district court the following year but lost. 
 
The Wyoming Supreme Court ruled Monday that because the officers “were not engaged in the lawful performance of their official duties” when they entered Woods’ home without a warrant, none of the other issues needed to be addressed. 
 
In a previous ruling on Fourth Amendment rights, the Supreme Court stated that “a bright line has been drawn at the threshold of a person’s dwelling which cannot be crossed to effectuate the warrantless arrest of a suspect absent consent or exigent circumstances.” 
 
This case had no extenuating circumstances — Woods did not possess any weapons, did not pose an immediate threat to his ex-girlfriend and did not surrender his expectation of privacy when his wife answered a knock at the front door, the ruling states.
 
This story was published on April 18, 2023.