State of Minnesota v. Tara Renaye Molnau, A16-330

Police obtained a daytime warrant to search Nicholas Zobel’s home for methamphetamine based on a tip and witness statements linking Zobel to recent meth purchases and prior drug convictions.
Officers executed the warrant at 3:08 p.m.; they entered after announcing and apprehended Zobel inside the house. Tara Molnau was found sitting on the living-room couch.
A purse on the kitchen table contained Molnau’s ID and 4.002 grams of methamphetamine; an officer searched the purse without asking Molnau’s permission, relying on the home search warrant.
Officers also found additional methamphetamine and drug paraphernalia elsewhere in the house.
Molnau moved to suppress the evidence from the purse, arguing lack of probable cause to search her personal property; the district court denied suppression and convicted her of third-degree possession after a stipulated evidence trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether searching a visitor’s purse found in the home during execution of a valid warrant required independent probable cause	Molnau: purse was her personal property and searching it without independent probable cause violated her Fourth Amendment rights	State: purse was not in Molnau’s immediate possession and could reasonably contain items described in the warrant, so it fell within the warrant’s scope	Search lawful: purse was off-person and located in the house where officers found other drugs; therefore covered by the warrant
Whether officers should have recognized the purse belonged to a visitor and refrained from searching	Molnau: purse likely belonged to her (only female present), so visitor privacy warranted protection	State: applicant had information another woman lived at the residence; officers reasonably could search containers in the home	Not dispositive: presence of other indicia and discovered contraband undermined argument—search remained lawful

State v. Ruoho, 685 N.W.2d 451 (Minn. App. 2004) (standard for appellate review of suppression rulings)
State v. Wills, 524 N.W.2d 507 (Minn. App. 1994) (containers in a residence may be searched if they could conceal items described in the warrant)
State v. Couillard, 641 N.W.2d 298 (Minn. App. 2002) (upholding search of a visitor’s unattended backpack found in the living area during a residence search)
Ybarra v. Illinois, 444 U.S. 85 (U.S. 1979) (warrant to search premises does not automatically authorize search of persons present without individualized probable cause)
State v. Wynne, 552 N.W.2d 218 (Minn. 1996) (search warrant for a building does not permit searching all persons found there)
State v. Kelley, 832 N.W.2d 447 (Minn. App. 2013) (appellate court role as error-correcting court; cited regarding reliance on precedent)