Andrews v. State
In Andrews v. State, 40 P.3d 708, 715 (Wyo. 2002), the Court reiterated that the Wyoming Constitution allows searches incident to arrest and can be said to allow automobile searches for evidence related to the crime because the arrestee had possession of it.
The Court also reiterated, however, that searches must be reasonable under all of the circumstances.
The Court said searches incident to arrest performed for the permissible reasons of locating weapons or evidence related to the crime are reasonable under Wyoming's search and seizure provision. Id.
On the basis of these principles, the Court affirmed a denial of a suppression motion in Andrews where, after being told he was under arrest, the defendant removed the wallet from his pocket and laid it on the kitchen counter directly in front of him.
The deputy picked it up and searched it.
The Court concluded it was reasonable and appropriate for the officer to seize the wallet and search it for weapons and/or evidence.