State v. Williams
794 N.W.2d 867
Minn.2011Background
- Police responded to armed-robbery report; suspect described as tall Black man in black hoodie, last seen running west from 22nd St and Emerson Ave N, Minneapolis.
- Officer Andersen pursued Williams during lawful investigatory stop and observed the butt of a pistol protruding from Williams’s sweatshirt pocket.
- Williams acknowledged the pistol and the officer recovered a loaded .38-caliber revolver from Williams’s pocket.
- The robbery victim could not identify Williams; Williams was arrested for unlawful possession of a firearm in a public place.
- At the jail, Williams surrendered cocaine to the arresting officer; Williams stated the cocaine was worth $60 and that he carried the pistol for protection.
- Williams was charged with fifth-degree possession of a controlled substance and faced a 36-month mandatory minimum sentence under Minn. Stat. § 609.11 when the State alleged the offense occurred while in possession of a firearm.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether probable cause supported arrest for possessing a pistol in public | Williams asserts lack of probable cause given no permit check | State maintains observations and admissions established probable cause | Probable cause existed to arrest Williams for § 624.714, subd. la |
| Whether the Second Amendment affects the probable-cause analysis | Heller framework could require different construction | Court rejected applying Heller to probable-cause in this context | Not addressed; interests of justice do not require answering the new Second Amendment claim |
| Whether the opinion should redefine the elements of the offense or the permit defense | Not explicitly argued at district court; seeks broader rule | Timberlake/Paige interpretations applied; no new rule announced | Court limits holding to facts of this case; does not define precise contours for all cases |
Key Cases Cited
- State v. Paige, 256 N.W.2d 298 (Minn. 1977) (permit language not element; offense satisfied by possession in public place)
- Timberlake, 744 N.W.2d 390 (Minn. 2008) (informant tip supports reasonable, articulable suspicion; statute interpreted with permit as defense)
- Ortega, 770 N.W.2d 145 (Minn. 2009) (probable cause standard applies to warrantless arrests)
- In re Welfare of G.M., 560 N.W.2d 687 (Minn. 1997) (probable cause and totality-of-circumstances test)
- Horner, 617 N.W.2d 789 (Minn. 2000) (probable cause requires more than mere suspicion)
- State v. Riley, 568 N.W.2d 518 (Minn. 1997) (objective totality-of-circumstances analysis for probable cause)