State of Minnesota v. Todd Eugene Trahan, 2016 Minn. LEXIS 660

Background

At 12:34 a.m. on Oct. 24, 2012, Ramsey County deputies stopped Todd Trahan for speeding and erratic driving; officers observed signs of intoxication and arrested him.
Trahan was taken to jail; after being read the implied-consent advisory, officers requested urine or blood tests (no warrant was obtained).
Trahan provided a urine sample that officers believed was tampered with and later refused a requested blood draw at about 2:40 a.m.; he was charged with first-degree test refusal under Minn. Stat. § 169A.20, subd. 2.
Trahan pleaded guilty, later sought postconviction relief arguing the test-refusal conviction was unconstitutional under McNeely and later Birchfield; courts ultimately revisited the conviction after Bernard and Birchfield were decided.
The Minnesota Supreme Court assessed (1) whether a warrant or exigent circumstances were required for a blood draw, (2) whether exigent circumstances existed here, and (3) whether the good-faith exception saved the conviction.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Trahan)	Held
Whether convicting for refusal to submit to a warrantless blood test violates the Fourth Amendment	Statute is constitutional; refusal may be criminal even without a warrant	Conviction violates Fourth Amendment if blood draw would be unconstitutional	Under Birchfield, State cannot prosecute refusal to a warrantless blood draw absent a warrant or exigency — conviction unconstitutional as applied
Whether exigent circumstances justified a warrantless blood draw	Delay in cooperation (urine issue, late refusal) created exigency; officers could not obtain usable sample within 2-hour window	No exigency: 2-hour window already lapsed by refusal time; Trahan was in custody and available; warrant could have been sought during transport	No exigent circumstances existed; State failed its burden to show emergency justified warrantless blood draw
Whether the good-faith exception to the exclusionary rule applies	Officer reasonably relied on binding precedent; good-faith exception should prevent overturning conviction	Good-faith exception is evidence-rule based and inapplicable because Trahan did not seek suppression of evidence	Good-faith exception does not apply here because defendant challenges conviction (not suppression) and no evidence from the blood draw was used
Whether Minn. Stat. § 169A.20, subd. 2 is constitutional as applied	Statute validly punishes refusal to submit to chemical tests	Statute unconstitutional as applied where test would be an unreasonable search	Statute is unconstitutional as applied to Trahan’s refusal of a warrantless blood test; conviction reversed/affirmed in favor of Trahan

Key Cases Cited

Birchfield v. North Dakota, 136 S. Ct. 2160 (2016) (SCOTUS: breath tests permissible incident to arrest; warrantless blood tests require warrant or exigent circumstances; criminalizing refusal to unlawful blood test invalid)
McNeely v. Missouri, 133 S. Ct. 1552 (2013) (SCOTUS: exigency is a case-by-case inquiry; natural metabolization of alcohol does not create per se exigency)
State v. Bernard, 859 N.W.2d 762 (Minn. 2015) (Minn. decision addressing test-refusal statutes and search-incident-to-arrest analysis)
State v. Stavish, 868 N.W.2d 670 (Minn. 2015) (Minn.: exigent-circumstances analysis, 2‑hour evidentiary window, medical emergency supported warrantless draw)
State v. Lindquist, 869 N.W.2d 863 (Minn. 2015) (Minn.: good-faith exception framework when officers rely on binding precedent)
Welsh v. Wisconsin, 466 U.S. 740 (1984) (SCOTUS: government bears burden to show exigent circumstances)
Mincey v. Arizona, 437 U.S. 385 (1978) (SCOTUS: exigencies can make warrantless searches reasonable under the Fourth Amendment)
Davis v. United States, 564 U.S. 229 (2011) (SCOTUS: good-faith exception when officers reasonably rely on binding precedent)
United States v. Calandra, 414 U.S. 338 (1974) (SCOTUS: exclusionary rule is a judicially created rule of evidence)