State of Minnesota v. Christopher Davis Schultz
A16-606
| Minn. Ct. App. | Jan 17, 2017Background
- In Nov. 2014 officers executed a search warrant at J.H.’s residence and found evidence of a recently dismantled marijuana grow (equipment, ventilation, dried clippings, paraphernalia).
- J.H., the tenant, admitted involvement, said he dumped a crop, and told police Schultz financed the operation, visited weekly, and received multiple pounds of marijuana every few months in exchange for financing.
- Officers corroborated J.H.’s descriptions of Schultz, located receipts at J.H.’s home bearing Schultz’s name/address/phone for items consistent with grow operations, and began surveilling Schultz the same day.
- When Schultz left his residence police stopped and arrested him without a warrant; a search incident to arrest yielded suspected cocaine on his person and additional narcotics in his car (~160 grams).
- Schultz moved to suppress, arguing the warrantless arrest lacked probable cause; the district court denied suppression, and Schultz was convicted after a stipulated-facts trial. He appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether police had probable cause to make a warrantless public arrest of Schultz | State: J.H.’s statements, corroborated by receipts and J.H.’s admissions against interest, provided probable cause that Schultz participated in the grow scheme | Schultz: J.H.’s tip was unreliable and insufficient to establish probable cause for arrest | Held: Probable cause existed based on the totality of circumstances (J.H.’s recent personal observations, corroboration, and statements against interest) |
| Whether evidence from searches incident to the arrest should be suppressed as fruit of an unlawful arrest | State: Because the arrest was lawful, ensuing searches were valid | Schultz: The arrest was unlawful so subsequent searches and seized evidence must be suppressed | Held: Arrest lawful; searches and seized narcotics admissible |
| Whether police were required to identify a specific felony before effecting the warrantless arrest | State: No separate pronouncement required; probable-cause suffices | Schultz: Police never identified the requisite felony prior to arrest, so arrest unconstitutional | Held: Court declines to entertain procedural-continuance argument; on merits probable cause to believe felony conduct existed, so arrest valid |
| Standard of review for probable-cause determination | State: Probable cause judged under totality-of-circumstances; reviewed de novo | Schultz: N/A (challenges sufficiency of facts) | Held: Probable cause reviewed de novo; applied totality test and affirmed |
Key Cases Cited
- Wong Sun v. United States, 371 U.S. 471 (1963) (evidence obtained by exploitation of illegal police conduct may be excluded)
- State v. Onyelobi, 879 N.W.2d 334 (Minn. 2016) (probable cause defined under Minnesota law)
- State v. Dickey, 827 N.W.2d 792 (Minn. App. 2013) (warrantless arrests in public places permitted with probable cause)
- State v. Albrecht, 465 N.W.2d 107 (Minn. App. 1991) (informant veracity and basis of knowledge relevant to probable-cause analysis)
- State v. Wiberg, 296 N.W.2d 388 (Minn. 1980) (statements against interest enhance an informant's reliability)