State v. Molnau, 904 N.W.2d 449

In April 2015 police obtained a warrant to search N.Z.’s home and person for methamphetamine, paraphernalia, and evidence of drug trafficking; the application noted a woman (M.L.D.) lived there but gave no other info about her.
Officers executed the warrant at N.Z.’s residence and found Tara Molnau (a guest) in the living room; searches of rooms uncovered marijuana, methamphetamine, and a purse on the kitchen table.
The unattended purse contained .4002 grams of methamphetamine and Molnau’s ID.
Molnau was charged under Minnesota law for third-degree controlled-substance possession based solely on the methamphetamine found in the purse.
Molnau moved to suppress, arguing the search of her purse (as a guest’s personal property not in her possession) exceeded the scope of the premises warrant; the district court and court of appeals denied suppression.
The Minnesota Supreme Court granted review to decide whether the warranted premises search lawfully extended to a guest’s unattended purse under the Fourth Amendment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether searching a guest’s unattended purse during execution of a premises warrant violated the Fourth Amendment	Molnau: as a guest not named in the warrant she retained a reasonable expectation of privacy in her purse; warrant did not authorize searching her belongings	State: the purse was unattended, capable of concealing the contraband described in the warrant, and officers did not know its owner—so it fell within the scope of the premises warrant	The search was reasonable under the totality of the circumstances and did not violate the Fourth Amendment; suppression was properly denied

Horton v. California, 496 U.S. 128 (warrant limits searches; evidence outside scope requires reasonableness analysis)
United States v. Ross, 456 U.S. 798 (a warrant authorizes searching containers officers reasonably believe could hold items described in the warrant)
Ybarra v. Illinois, 444 U.S. 85 (premises warrant does not authorize searching persons not named in the warrant)
Riley v. California, 573 U.S. 373 (warrantless searches are presumptively unreasonable)
Wyoming v. Houghton, 526 U.S. 295 (automobile-search principles and passenger belongings; not controlling for premises searches)
State v. Wynne, 552 N.W.2d 218 (Minn. 1996) (a purse carried by a person is an extension of the person and protected from a premises warrant when in that person’s possession)