State of Minnesota v. Jimmy Dawayne Lester, 874 N.W.2d 768

On Oct. 26, 2011, a long-term confidential reliable informant (CRI) told MPD Officer Kyle Ruud that a man nicknamed “J.” would deliver a quantity of heroin to Broadway Ave N and Washington Ave N within about ten minutes.
Within minutes officers observed a man matching J.’s description as a passenger in a Dodge Charger driven by Jimmy Dawayne Lester; the CRI positively identified the passenger as J.
J. exited the Charger, paced and looked around (while on a phone), crossed to a McDonald’s lot, and entered a silver Pontiac Grand Am after meeting its occupant; Lester remained with the Charger nearby.
Officer Ruud, based on the CRI tip plus his training and experience with narcotics patterns ( one person staying with a vehicle while another deals), inferred J. was making a drug sale and that Lester’s vehicle likely contained heroin.
Police stopped the Grand Am and searched the Charger, finding bindles of heroin concealed in the Charger’s center console; district court denied Lester’s suppression motion, convicted him of third-degree possession, and acquitted him of second-degree sale.
The court of appeals reversed suppression denial; the Minnesota Supreme Court granted review and reversed the court of appeals, holding the automobile exception supported the warrantless car search.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless search of Lester’s car was lawful under the automobile exception	CRI tip corroborated by officers + officer’s training-based inferences produced probable cause that the car contained heroin	Probable cause dissipated once J. left the car; officer inferences insufficient to support car search	Yes. Totality of circumstances (reliable CRI, corroboration, officer observations and inferences) established probable cause for automobile-exception search

State v. Munson, 594 N.W.2d 128 (Minn. 1999) (standard of review and warrantless-search exceptions)
State v. Search, 472 N.W.2d 850 (Minn. 1991) (automobile-exception allows search of vehicle and closed containers with probable cause)
United States v. Ross, 456 U.S. 798 (1982) (automobile exception extends to containers within vehicle)
State v. Johnson, 277 N.W.2d 346 (Minn. 1979) (probable cause definition for vehicle searches)
State v. Williams, 794 N.W.2d 867 (Minn. 2011) (totality-of-circumstances inquiry for probable cause)
State v. Perkins, 582 N.W.2d 876 (Minn. 1998) (probable cause analysis)
State v. Lee, 585 N.W.2d 378 (Minn. 1998) (common-sense approach to probable cause)
State v. Koppi, 798 N.W.2d 358 (Minn. 2011) (weight given to officer training and experience in probable-cause determinations)
State v. Harris, 590 N.W.2d 90 (Minn. 1999) (police may draw inferences unavailable to untrained observers)
Ornelas v. United States, 517 U.S. 690 (1996) (review framework; give due weight to officer inferences)
State v. Horner, 617 N.W.2d 789 (Minn. 2000) (crediting officer credibility and inferences in probable-cause analysis)
Chambers v. Maroney, 399 U.S. 42 (1970) (validity of arrest not dispositive when vehicle search is supported by probable cause)