The Wyoming Supreme Court affirmed a methamphetamine possession conviction Thursday, rejecting the defendant's challenge to a search warrant that led to the discovery of drugs in his bedroom. The court held that law enforcement did not omit material facts from the search warrant affidavit that would have undermined probable cause.
Chad Everette Urrutia had entered a conditional guilty plea to possession of methamphetamine while preserving his right to appeal the underlying search. The charge stemmed from a search of a single-wide trailer where Urrutia lived with two other occupants. During the search, police found methamphetamine and drug paraphernalia in a bench located in Urrutia's bedroom.
The case originated in Campbell County District Court under Judge Matthew F.G. Castano. Urrutia's conditional plea allowed him to challenge the search while accepting responsibility for the charge, a common legal strategy that preserves appellate rights on constitutional issues.
On appeal, Urrutia argued the district court erred in denying his motion to suppress the evidence discovered during the search. His central contention was that law enforcement omitted material facts from the search warrant affidavit for the home. Urrutia maintained that if these facts had been included in the affidavit, law enforcement would not have had probable cause to search his bedroom.
The Wyoming Supreme Court disagreed with Urrutia's arguments in a decision issued Jan. 23, 2026. Writing for the court, Justice Jarosh found no error in the district court's handling of the suppression motion. The court's analysis focused on whether the omitted information would have been material to the probable cause determination.
Search warrant challenges frequently center on the adequacy of the supporting affidavit and whether law enforcement provided sufficient information to justify the intrusion. Courts must balance law enforcement's need to investigate crimes against individuals' Fourth Amendment protections against unreasonable searches and seizures.
In drug cases, the location and scope of searches become particularly important when defendants share living spaces with others. The fact that Urrutia lived in the trailer with two other occupants likely complicated the probable cause analysis, as courts must consider whether evidence supports searching specific areas versus common spaces.
The discovery of methamphetamine and drug paraphernalia in a bench in Urrutia's bedroom suggests law enforcement had sufficient justification to search that specific area. The Wyoming Supreme Court's affirmation indicates the warrant provided adequate probable cause even considering any omitted information.
Conditional guilty pleas serve an important function in the criminal justice system by allowing defendants to accept responsibility while preserving their right to challenge constitutional violations. This mechanism prevents cases from proceeding to lengthy trials when the primary dispute concerns the admissibility of evidence rather than guilt or innocence.
The case was argued before the full Wyoming Supreme Court, including Chief Justice Boomgaarden and Justices Gray, Fenn, Jarosh, and Hill. Urrutia was represented by the Office of the State Public Defender, with Senior Assistant Appellate Counsel Sean Barrett handling oral arguments. The state was represented by the Wyoming Attorney General's office, with Assistant Attorney General Leanne Johnston arguing the case.
The decision reflects ongoing tensions in Fourth Amendment jurisprudence between effective law enforcement and constitutional protections. Courts must carefully review search warrant applications to ensure they contain sufficient factual basis while recognizing that perfect information is rarely available during investigations.
For practitioners, the case reinforces the importance of thorough warrant applications and the difficulty of succeeding on omission-based challenges to search warrants. The Wyoming Supreme Court's affirmation suggests that omitted facts must be truly material to the probable cause determination to warrant suppression.
The ruling also highlights the strategic considerations defendants face when deciding whether to enter conditional guilty pleas. While this approach preserved Urrutia's appellate rights, it ultimately did not result in suppression of the evidence or reversal of his conviction.
This case represents one example of how state supreme courts address Fourth Amendment issues in drug prosecutions. The Wyoming Supreme Court's decision contributes to the body of state law interpreting search and seizure protections, particularly in cases involving shared living spaces and warrant omissions.
The affirmation means Urrutia's conviction stands, and the evidence found during the search remains admissible. The decision provides guidance for future cases involving similar challenges to search warrant adequacy and law enforcement's duty to include material facts in warrant applications.