State of Minnesota v. Kevin Ryan, A16-0473

On May 29, 2015, Blaine police stopped Kevin Ryan for a vehicle with a headlight out; Ryan produced an expired insurance card and was cited for operating without proof of insurance under Minn. Stat. § 169.791, subd. 2.
Ryan was charged with a petty misdemeanor; a bench trial was held on February 16, 2016.
Ryan did not request discovery before trial and presented no evidence. At trial he requested the officer’s audio/video recording, but the prosecutor said such tapes are routinely destroyed after six months and none was available.
The district court found Ryan guilty and imposed a $285 fine. Ryan appealed pro se.
On appeal Ryan argued (1) the statute is unconstitutional and (2) the state unconstitutionally destroyed evidence (the officer’s recording) and violated discovery rules. The court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Constitutionality of Minn. Stat. § 169.791, subd. 2 (insurance-proof requirement) and whether it may be raised on appeal	Ryan argued the statute violates the Minnesota Constitution (right to travel, due process)	State noted Ryan did not raise constitutional objections in district court and relied on precedent upholding the statute	Court held Ryan forfeited the constitutional challenge by not raising it below; declined to reach it on the merits but cited controlling precedent upholding the statute
2. Destruction of officer’s recording: constitutional due-process violation and discovery rule breach	Ryan argued destruction deprived him of exculpatory evidence and violated Minn. R. Crim. P. 9.04	State said tapes are routinely destroyed after six months and none was in its possession/control at trial; it provided available investigatory report/citation notation	Court applied Trombetta/Hawkinson framework: Ryan made no showing tape had apparent, material exculpatory value; no bad faith or improper motive; destruction followed routine procedures; no constitutional or discovery violation

Roby v. State, 547 N.W.2d 354 (Minn. 1996) (appellate courts generally will not consider constitutional issues not raised below)
In re Welfare of C.L.L., 310 N.W.2d 555 (Minn. 1981) (declining to address constitutional issue raised first on appeal)
Dale v. State, 535 N.W.2d 619 (Minn. 1995) (appellate consideration of pro se criminal defendant’s arguments)
State v. Cuypers, 559 N.W.2d 435 (Minn. App. 1997) (upholding automobile-insurance proof statute against right-to-travel and due-process challenges)
California v. Trombetta, 467 U.S. 479 (U.S. 1984) (government duty re: preservation of exculpatory evidence; apparent materiality standard)
State v. Hawkinson, 829 N.W.2d 367 (Minn. 2013) (Minnesota standard for evaluating destruction of evidence—apparent/material exculpatory value and bad-faith analysis)