State of Minnesota v. Matthew Vaughn Diamond, 890 N.W.2d 143

On Oct. 30, 2014, homeowner M.H. discovered her garage side-entry door kicked in and jewelry and other items missing; an envelope with S.W.’s name was found in the driveway.
Police linked pawned jewelry to S.W.; on Nov. 4 officers found S.W.’s car with appellant Matthew Diamond driving; Diamond was arrested on an unrelated warrant and booked at the county jail where officers collected his shoes and cellphone.
Detective Nelson viewed Diamond’s seized property at the jail, noted shoe-tread similarities to prints at the scene, instructed jail staff not to release the property, then obtained warrants to seize the shoes and phone and later to search the phone’s contents.
The phone was locked; the state moved to compel Diamond to provide a fingerprint/thumbprint to unlock it. The district court ordered him to comply; Diamond initially refused, was held in civil contempt, then provided a print and police searched the phone.
Diamond was convicted by a jury of second-degree burglary, misdemeanor theft, and fourth-degree criminal damage; he appealed, raising (1) Fourth Amendment seizure claims, (2) Fifth Amendment compulsion claims re: fingerprinting to unlock the phone, and (3) sufficiency of the circumstantial evidence.

Issue	State's Argument	Diamond's Argument	Held
1. Were the temporary seizure and retention of Diamond’s shoes and phone lawful under the Fourth Amendment?	Seizure was justified by exigent circumstances to preserve potential evidence while a warrant was sought.	Nelson’s viewing of the property at the jail rendered the seizure an unreasonable warrantless search/seizure.	Affirmed: temporary seizure justified by exigency; viewing did not render seizure unlawful.
2. Did ordering Diamond to provide his fingerprint to unlock the phone violate the Fifth Amendment?	Providing a fingerprint is nontestimonial physical evidence (like fingerprints, blood, voice exemplars) and not protected by the Fifth Amendment.	Compelled fingerprinting to unlock the phone is testimonial because it implicitly communicates control/knowledge and effectively identifies exclusive use.	Affirmed: compelled fingerprinting was nontestimonial and did not violate the Fifth Amendment.
3. Was the circumstantial evidence sufficient to support convictions for burglary, theft, and damage?	The totality of evidence (shoe-tread match, phone location pings, pawned jewelry, S.W.’s testimony, ID in S.W.’s car, communications) supports guilt beyond rational alternative.	Evidence could be consistent with merely transferring stolen property (i.e., not the burglar).	Affirmed: record contained sufficient circumstantial evidence excluding rational innocent hypotheses.

Mapp v. Ohio, 367 U.S. 643 (incorporation of Fourth Amendment exclusionary rule)
Illinois v. McArthur, 531 U.S. 326 (temporary seizure to prevent destruction while obtaining warrant)
Riley v. California, 573 U.S. 373 (cellphone searches implicate privacy; warrants required to search contents)
United States v. Jacobsen, 466 U.S. 109 (definition of "search" and interference with possessory interests)
United States v. Place, 462 U.S. 696 (temporary seizure of property to preserve evidence pending warrant)
Schmerber v. California, 384 U.S. 757 (compulsion to produce physical evidence is not testimonial under Fifth Amendment)
Doe v. United States, 487 U.S. 201 (testimonial requirement: compelled communication must disclose facts or assertions)
Horst v. State, 880 N.W.2d 24 (Minn. 2016) (cellphone seizure pending warrant justified by potential for quick destruction of data)
Fisher v. United States, 425 U.S. 391 (distinguishing testimonial communications from physical evidence)