State of Minnesota v. Jimmy Clyde Griffin, A15-1921

Griffin, a probationer banned from possessing firearms and non-prescribed controlled substances, was arrested after his probation officer searched his apartment based on two citizen tips claiming he had drugs (in a black backpack) and a ".38-caliber" gun in a desk drawer.
The probation officer consulted a district judge and then conducted a warrantless search; a pellet gun and marijuana were found.
Griffin moved to suppress; the district court denied the motion and the jury convicted him of possession of a firearm by an ineligible person (Minn. Stat. § 624.713) and fifth-degree controlled-substance possession.
On appeal Griffin challenged (1) the legality of the warrantless probation search, (2) jury instructions treating pellet/BB guns as firearms, (3) a clarification that the state need not prove the defendant knew the item was legally a firearm, and (4) sufficiency of the evidence because the weapon was a pellet gun.
The Court of Appeals affirmed: the search was supported by reasonable suspicion, the jury instructions correctly stated the law, and the evidence was sufficient to convict because pellet guns qualify as "firearms" under existing Minnesota precedent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legality of warrantless probation search	Probation officer lacked reasonable suspicion to search; suppression required	Two independent citizen tips (identifiable, voluntary, based on personal observation) provided reasonable suspicion for a search of a probationer subject to a search condition	Search reasonable under Knights/Anderson; denial of suppression affirmed
Separation-of-powers / judge authorization of search	Judge advising/authorizing the probation search violated separation of powers	Probation officers act under court orders; judge consultation was permissible and did not prejudice Griffin	Claim not properly preserved but rejected on merits; consultation was permissible
Jury instruction: pellet/BB guns are firearms	Instruction removed element from jury and unlawfully directed verdict	Precedent (Seifert, Fleming, Haywood) treats BB/pellet guns as firearms under Minnesota law; court must instruct on law	Instruction was legally correct and not an improper direction of verdict
Mens rea: must state know item is a "firearm" under law	Griffin: state must prove he knew the pellet gun was a firearm as defined by Minnesota law	Mens rea requires knowledge of possession, not knowledge of legal classification; ignorance of law is not a defense	Court correctly instructed that “knowingly” refers to possession only; no requirement that defendant know statutory classification

Griffin v. Wisconsin, 483 U.S. 868 (U.S. 1987) (probation-search special needs justify departures from warrant/probable cause)
United States v. Knights, 534 U.S. 112 (U.S. 2001) (reasonableness of probation searches balanced under diminished privacy/need)
State v. Anderson, 733 N.W.2d 128 (Minn. 2007) (adopting Knights framework for Minnesota probation searches)
State v. Seifert, 256 N.W.2d 87 (Minn. 1977) (adopting game-and-fish definition of firearm to include air-powered guns)
State v. Fleming, 724 N.W.2d 537 (Minn. App. 2006) (holding BB gun qualifies as a firearm under Minn. Stat. § 624.713)
State v. Haywood, 869 N.W.2d 902 (Minn. App. 2015) (treating BB gun as firearm under statute prohibiting firearms possession by violent-felony convicts)
State v. Moore, 699 N.W.2d 733 (Minn. 2005) (instructional error where a jury was told a factual question was established as a matter of law)
State v. Ndikum, 815 N.W.2d 816 (Minn. 2012) (imputing a mens rea element requiring knowledge of possession when statute silent)