March 6, 2024, Minnesota Supreme Court Caselaw Update
This week, the Minnesota Supreme Court released opinions in two criminal cases.
First, in State v. Malecha, ___ N.W.3d ___, 2024 WL 949625 (Minn. Mar. 6, 2024), the Minnesota Supreme Court addressed whether Minnesota’s narrowly defined good-faith exception should be expanded.
The court framed the issue as follows:
whether the good-faith exception to the exclusionary rule under the Minnesota Constitution, adopted for the first time in Minnesota in State v. Lindquist, 869 N.W.2d 863, 876–77 (Minn. 2015), should apply to evidence obtained during a search and arrest incident to a quashed warrant that appears active to law enforcement because of a clerical court error.
The court declined to expand the good faith exception and reaffirmed that, under the Minnesota Constitution, the good faith exception is limited to one circumstance: when law enforcement obtains evidence in reasonable reliance on binding appellate precedent that specifically authorizes the conduct at issue.
After determining that the good faith exception did not apply, the court reversed the court of appeals’ decision expanding the good-faith exception and reinstated the district court’s order dismissing the charges against Malecha.
Rice County; state pre-trial appeal; controlled substance crimes
OPA221314-030624.pdf (mncourts.gov)
Second, in State v. Venengen, ___N.W.3d___, 2024 WL 949629 (Minn. Mar. 6, 2024), the Minnesota Supreme Court concluded that when the factfinder finds beyond a reasonable doubt that a sexual assault of a physically helpless complainant happened within the complainant’s zone of privacy—the bedroom— the district court has discretion to impose an upward departure. The court rejected the argument that a departure is not warranted in such situations because criminal sexual conduct offenses involving sleeping complainants typically happen within the person’s zone of privacy—the bedroom. The court affirmed the sentencing departure.
Hennepin County; Jury trial; third-degree criminal sexual conduct against a physically helpless person; Minnesota Statutes section 609.344, subdivision 1(d) (2020).
