State of Minnesota v. Debra Lee Fawcett, 884 N.W.2d 380

Background

On May 24, 2014, Debra Fawcett ran a red light and collided with another vehicle, causing the other driver to suffer significant leg/foot injuries.
Officers at the scene smelled alcohol on Fawcett and she admitted to having "two to three beers;" she was transported to a hospital where police sought a blood sample.
A detective obtained a warrant authorizing a blood draw and to "forward said blood sample to an approved lab for testing," incorporating an affidavit describing the crash, injuries, eyewitness placement of Fawcett as the driver, the odor of alcohol, and the officers’ belief she was under the influence.
The preliminary breath test and later BCA reports showed no ethyl alcohol but did detect THC metabolite and Alprazolam in Fawcett’s blood; the State charged Fawcett with criminal vehicular operation under Minn. Stat. § 609.21, subd. 1(2) (2012).
Fawcett moved to suppress all drug-evidence, arguing the warrant affidavit established probable cause only for alcohol testing and that allowing drug testing exceeded the warrant’s scope and violated the Fourth Amendment particularity requirement.
The district court granted suppression as to drug testing; the court of appeals reversed; the Minnesota Supreme Court affirmed the warrant and testing for controlled substances.

Issues

Issue	Plaintiff's Argument (Fawcett)	Defendant's Argument (State)	Held
Whether the warrant affidavit supplied probable cause to test blood for controlled substances	Affidavit referenced only alcohol indicators (smell, admission); thus probable cause supported only alcohol testing, not drug testing	Probable cause to find evidence of criminal vehicular operation (which may be caused by alcohol, controlled substances, or both) supports testing for intoxicants generally	Held: Probable cause supported testing for alcohol and controlled substances given totality of circumstances and statutory elements of the offense
Whether a warrant authorizing sending blood to “an approved lab for testing” was insufficiently particular	Broad lab-testing language allowed general exploratory testing (e.g., DNA, medical conditions), violating the Particularity Clause	Incorporation of the affidavit limited testing to evidence of criminal vehicular operation (alcohol and/or controlled substances); more precise description was not practicable	Held: Warrant was sufficiently particular when read with the incorporated affidavit — testing limited to evidence of the charged crime
Whether seizure of the blood extinguished expectation of privacy in its contents	Court of appeals had held seizure eliminated privacy; Fawcett argued retained privacy in blood contents and testing scope matters	State argued post-seizure testing for evidentiary toxicology is permissible	Held: Supreme Court agreed Fawcett retained some privacy but resolved case on probable cause/particularity grounds and did not adopt broad rule that seizure eliminates all privacy
Whether evidence should be excluded under good-faith doctrines (raised in dissent)	N/A at majority level (Fawcett urged suppression)	Even if probable cause was lacking, officers may have relied in good faith on a facially valid warrant	Dissent discussed good-faith exception; majority did not rely on it to decide the case

Key Cases Cited

Illinois v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances test for probable cause; magistrate may draw reasonable inferences)
Groh v. Ramirez, 540 U.S. 551 (2004) (warrant may be construed with incorporated affidavit when accompanied)
Skinner v. Ry. Labor Execs' Ass'n, 489 U.S. 602 (1989) (blood/chemical analysis can reveal highly personal medical information)
State v. Rochefort, 631 N.W.2d 802 (Minn. 2001) (standard of review for magistrate’s probable-cause determination)
State v. Wiley, 366 N.W.2d 265 (Minn. 1985) (consider totality of circumstances; avoid isolating affidavit components)
State v. Jenkins, 782 N.W.2d 211 (Minn. 2010) (magistrate’s practical, commonsense probable-cause role)
State v. Hannuksela, 452 N.W.2d 668 (Minn. 1990) (warrant language can meet minimal particularity under case circumstances)
State v. Paul, 548 N.W.2d 260 (Minn. 1996) (driving conduct can support probable cause of impairment by an intoxicant)