The state Supreme Court ruled that Fourth Amendment protections are extended to civil actions, not just criminal ones.
In two unanimous rulings, the Minnesota Supreme Court on Wednesday curbed law enforcers’ ability to search and seize personal possessions.
The more significant ruling, written by Justice Christopher Dietzen, extended U.S. constitutional protections against unreasonable search and seizure to Minnesota civil, not just criminal, matters.
The second ruling determined that police had illegally impounded and searched a properly parked vehicle.
Teresa Nelson, a lawyer for the ACLU of Minnesota, praised the rulings as having shored up Fourth Amendment rights. “Both of these decisions are a check on police authority,” she said.
In both cases, police found drugs while searching vehicles whose impoundments were later found to be illegal. Evidence obtained during such searches can’t be used in court. That legal principle — the so-called exclusionary rule — has long covered criminal and civil proceedings under U.S. Supreme Court rulings. The state high court, however, had yet to explicitly decide whether the rule applied to civil cases in Minnesota.
Now it has.
The rulings reversed lower court decisions and sent the cases back for further action.
The first case was that of Daniel Garcia-Mendoza. In March 2012, he was stopped by Plymouth police while driving 63 miles per hour in a 60 mph zone. Police had checked the vehicle’s registration and found it registered to Ricardo Cervantes-Perez, an alias for Garcia-Mendoza.
When an officer asked for a driver’s license, Garcia-Mendoza presented a Mexican ID bearing the alias. He was ticketed for not having a driver’s license. The officer then had the vehicle searched and towed because it was creating a potential traffic hazard, the ruling said.
During a search of the vehicle, an officer found methamphetamine. Garcia-Mendoza was arrested. Officers found $611 in cash on him.
Garcia-Mendoza then filed a state civil claim seeking to regain possession of the vehicle and his cash.
In the following couple of months, he was indicted and pleaded guilty to a federal crime for distributing controlled substances dating back to a December 2011 incident. As part of the plea, he agreed to forfeit property obtained from or used to commit his crimes.
When Garcia-Mendoza returned to District Court to challenge the seizure of his cash and property, the judge said that the traffic stop was unconstitutional but the forfeiture could stand because he had agreed to it in his federal plea deal.
The case then went to the state Appeals Court. There, Garcia-Mendoza’s attorney argued that because the stop was illegal, police shouldn’t have been able to seize the property. He cited the exclusionary rule.
The Appeals Court disagreed, saying that the legal principle applies only to criminal proceedings, not civil ones such as Garcia-Mendoza’s forfeiture case.
But in Wednesday’s ruling, the state high court cited a 1965 U.S. Supreme Court decision for extending the exclusionary rule to civil matters.
The ACLU of Minnesota had supported Garcia-Mendoza’s argument that the rule should apply in civil cases as a balance to “perverse incentives” for law enforcers when a profit motive is injected into police seizure of private property. It referenced the notorious case of the Metro Gang Strike Force, which repeatedly abused its forfeiture authority and cashed in on the proceeds from 2005 to 2009.
A second improper search
In the second ruling, the state Supreme Court said a police search of a properly parked vehicle that was improperly impounded was unreasonable.
In September 2012, a Blaine police officer stopped Erica Ann Rohde after seeing a signaling violation and determining that her driver’s license and registration were revoked. Although Rohde had safely parked on a residential street upon being stopped, police impounded her vehicle and conducted a search that yielded two small bags of meth and two glass pipes.
Rohde sought to suppress the evidence on the grounds that although the initial stop was proper, the search was unconstitutional because the impoundment was improper. The court agreed, saying that because Rohde had not been arrested and her parked vehicle posed no safety threat, the search was unreasonable.
It sent the case back to Anoka County District Court with instructions to suppress the evidence found during the car search.
Rochelle Olson • 612-673-1747