State of Minnesota v. Joseph Michael Galler, A16-1240

Officer observed Galler’s vehicle briefly (from ~2 blocks away at night for <1 second) and believed it exceeded a 30 mph limit; he gave no numeric speed estimate or verification.
Officer caught up on side streets, followed for less than a block, and was directly behind the vehicle.
Officer activated emergency lights once while beside the vehicle, then (per video) before the backseat passenger opened the door and exited. The passenger ran ~8–10 feet, reentered the vehicle seconds later, and the officer reactivated lights and stopped the vehicle.
District court found no reasonable suspicion for speeding but concluded the passenger’s conduct could indicate fleeing law enforcement and thus justified the stop.
Appellant moved to suppress evidence; district court denied motion; appellate court reviews suppression ruling de novo for reasonable articulable suspicion.

Issue	Galler's Argument	State's Argument	Held
Whether officer’s visual estimate of speeding supplied reasonable articulable suspicion to stop the vehicle	Officer’s brief nighttime observation without numeric estimate, training verification, or pacing could not reasonably support a speeding determination	Officer’s training and experience suffice to estimate speed visually	No — officer’s unparticularized, unsupported allegation of speeding did not supply reasonable suspicion
Whether passenger’s conduct (exiting and reentering) provided reasonable suspicion to justify the stop	Seizure occurred when officer first activated lights; conduct occurred after seizure and cannot be used to justify it	Passenger’s unusual conduct was independently suspicious and supports the stop	No — officer activated lights before passenger exited, so passenger conduct post-seizure cannot retroactively justify stop
Whether passenger’s brief exit and reentry purged any illegality of the initial seizure	The passenger’s quick submission did not create an intervening circumstance to cure unlawfulness	The conduct was suspicious enough to validate the stop regardless	No — brief nonresisting reentry is not an intervening circumstance that purges the taint of an unlawful seizure

United States v. Cortez, 449 U.S. 411 (1981) (particularized and objective facts required for reasonable suspicion)
Terry v. Ohio, 392 U.S. 1 (1968) (permitting brief investigatory stops supported by reasonable articulable suspicion)
State v. Diede, 795 N.W.2d 836 (Minn. 2011) (officer cannot rely on observations made after seizure to justify the seizure)
State v. Bergerson, 659 N.W.2d 791 (Minn. App. 2003) (flight after a seizure does not always purge illegality; facts can determine intervening-circumstance inquiry)
State v. Askerooth, 681 N.W.2d 353 (Minn. 2004) (seizure when a reasonable person would not feel free to leave)
State v. Gauster, 752 N.W.2d 496 (Minn. 2008) (standard of review for suppression rulings)