State of Minnesota, Respondent/Cross-Appellant v. Bonnie Ann Lindquist, Appellant/Cross-Respondent.
869 N.W.2d 863
| Minn. | 2015Background
- Lindquist was convicted of two counts of third-degree DWI based on a warrantless blood draw.
- The blood draw occurred after a motor-vehicle crash; Lindquist was purportedly the driver.
- The officer did not read implied-consent advisory or obtain a warrant or consent for the blood draw.
- Lindquist challenged the blood draw on direct review, arguing McNeely prohibits warrantless draws absent exigent circumstances.
- McNeely (2013) held that dissipation of alcohol alone is not a per se exigency; totality of the circumstances governs exigency.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lindquist can challenge under McNeely on direct appeal | Lindquist did not forfeit due to McNeely as intervening rule | State contends forfeiture; Linquist failed to object in district court | McNeely challenge was not forfeited |
| Whether to adopt the Davis good-faith exception | Davis exception should apply to Minnesota | Davis is incompatible with Minnesota law and Remedies Clause | Adopted strictly limited Davis good-faith exception for binding appellate precedent |
| Whether Remedies Clause requires suppression despite good-faith exception | Remedies Clause guarantees a remedy for constitutional violations | Remedies Clause does not require exclusion in all such cases | Remedies Clause requires a remedy; good-faith exception can be applied without violating it |
| Scope of section 626.21 vs. good-faith exception | Statutory remedy may coexist with good-faith exception | 626.21 precludes the good-faith approach | 626.21 does not preclude the Davis good-faith exception when properly limited |
| Application of good faith to the Lindquist facts | Shrink/Netland created single-factor exigency justifying blood draw | McNeely undermines prior shrink-based exemptions | Officer relied on binding Shriner and Netland; good-faith exception applied |
Key Cases Cited
- Missouri v. McNeely, 133 S. Ct. 1552 (U.S. 2013) (rejected per se exigency for warrantless blood draws; totality of circumstances governs)
- Davis v. United States, 131 S. Ct. 2419 (U.S. 2011) (adopted limited good-faith exception when binding appellate precedent existed)
- State v. Shriner, 751 N.W.2d 538 (Minn. 2008) (single-factor exigency for blood draw under prior Minnesota rule)
- State v. Netland, 762 N.W.2d 202 (Minn. 2009) (extended Shriner single-factor exigency to DWI cases)
- State v. Nolting, 312 Minn. 449 (Minn. 1977) (recognizes good-faith reliance in warrant context)
- Wiberg, 296 N.W.2d 388 (Minn. 1980) (manual balancing of exclusionary rule thresholds)
- Johnson v. State, 673 N.W.2d 144 (Minn. 2004) (exclusionary rule not automatic; harm analysis matters)
- Agin v. Heyward, 6 Minn. 110 (Minn. 1861) (Remedies Clause scope; rights vesting and enforcement)
- Baker v. Kelley, 11 Minn. 480 (Minn. 1866) (Remedies Clause prevents conditional enforcement of constitutionally protected rights)
- Davis v. Pierse, 7 Minn. 13 (Minn. 1862) (Remedies Clause guarantees remedy for injuries or wrongs)
- Olson v. Ford Motor Co., 558 N.W.2d 491 (Minn. 1997) (Remedies Clause scope; vesting of remedies)
- Hickman v. Group Health Plan, Inc., 396 N.W.2d 10 (Minn. 1986) (Remedies Clause limits and role of common-law rights)