State of Minnesota v. Roger Earl Holland
2015 Minn. LEXIS 367
| Minn. | 2015Background
- Holland was convicted of two counts of first-degree murder and two counts of second-degree murder for Margorie Holland's death and the death of her unborn child.
- Police seized Holland’s cell phone at the scene without a warrant; data were later recovered under a warrant after an initial review of text messages.
- The district court denied suppression motions, finding the cell-phone seizure was permissible; warrants were supported by probable cause.
- Pretrial, multiple warrants were issued to search electronic devices, Holland’s body, apartment, vehicles, and financial records.
- The medical examiner concluded Margorie’s death was a homicide by strangulation, with injuries not consistent with a fall down stairs; the timing of texts conflicted with Holland’s account.
- A juror was dismissed for cause after inconsistent statements and claimed intimidation; the conviction was affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the cell phone seizure complied with the plain-view doctrine | Holland: seizure lacked probable cause | State: plain-view justification supported by scene context | Yes; probable cause supported plain-view seizure |
| Whether the warrants had probable cause | Holland: affidavits lacked nexus to crime | State: affidavits established link to crime and target devices | Yes; warrants supported by probable cause |
| Whether the juror was properly dismissed for cause | Holland: improper timing and reliance on staff observations | State: Rule 26.02 and facts supported dismissal | Yes; not abuse of discretion under Rule 26.02(5)(1)·1 |
Key Cases Cited
- State v. Milton, 821 N.W.2d 789 (Minn. 2012) (plain-view probable-cause framework in Minnesota)
- State v. Zanter, 535 N.W.2d 624 (Minn. 1995) (plain-view with background knowledge)
- In re Welfare of G.M., 560 N.W.2d 687 (Minn. 1997) (plain-view applicability to incriminating nature)
- State v. DeWald, 463 N.W.2d 741 (Minn. 1990) (plain-view seizure when crime context present)
- Texas v. Brown, 460 U.S. 730 (1983) (background information may illuminate incriminating nature)
- Colorado v. Bannister, 449 U.S. 1 (1980) (infractions where recent crime context supports seizure)
- State v. Harris, 589 N.W.2d 782 (Minn. 1999) (probable-cause nexus for searches based on opportunity to commit crime)
- State v. Souto, 578 N.W.2d 744 (Minn. 1998) (nexus requirement for searches of devices)
- Riley v. California, 134 S. Ct. 2473 (2014) (telephone search rules; warrant required before search)
- State v. Moffatt, 450 N.W.2d 116 (Minn. 1990) (temporary seizure preservation of evidence)