MN: Evans rejected under state constitution; arrest on quashed warrant invalid

“Because we recognize several purposes served by the exclusionary rule, including deterring unlawful government conduct generally, and we conclude that applying the exclusionary rule here serves these remedial goals, we decline to extend the good-faith exception to the exclusionary rule under the Minnesota Constitution to the present facts. Therefore, we reverse the court of appeals and reinstate the district court’s order dismissing the charges against Malecha.” Arizona v. Evans is rejected under the state constitution. State v. Malecha, 2024 Minn. LEXIS 126 (Mar. 6, 2024):

Although Evans is analogous to the facts at hand, its holding addresses exclusion in the context of a violation of the Fourth Amendment to the U.S. Constitution. In contrast, here Malecha’s argument for exclusion is premised on a violation of Article I, Section 10, of the Minnesota Constitution. “In all cases, we employ our independent judgment in interpreting the Minnesota Constitution.” City of Golden Valley v. Wiebesick, 899 N.W.2d 152, 157 (Minn. 2017). We most often exercise this independent judgment in deciding whether to grant greater rights under our state constitution. See State v. Carter, 697 N.W.2d 199, 211 (Minn. 2005) (holding that a drug-detection dog sniff outside of a storage unit is a search under the Minnesota Constitution). But the mandate applies equally in determining whether a constitutional remedy, like exclusion, is available. See, e.g., Zanter, 535 N.W.2d at 634 (excluding evidence obtained in violation of Article I, Section 10, because “the good faith of the police … cannot cure the clear insufficiency of the … warrant application”); Garza v. State, 632 N.W.2d 633, 639-40 (Minn. 2001) (applying the exclusionary rule despite law enforcement’s good-faith reliance on an issued warrant because it lacked the “sufficiently particularized circumstances” required to justify an unannounced entry). Accordingly, Evans does not control here as to the remedy for a violation of the Minnesota Constitution. Instead, we must determine whether the good-faith exception applicable in Evans likewise applies under the Minnesota Constitution.

We have adopted the good-faith exception under the Minnesota Constitution in only one limited circumstance: when law enforcement officers obtain evidence in reasonable reliance on binding appellate precedent that specifically authorizes the police conduct at issue. Lindquist, 869 N.W.2d at 876. Since then, we have declined to extend the good-faith exception. See Leonard, 943 N.W.2d at 161 (“Because no binding appellate precedent authorizes a suspicionless search of a guest registry, the good-faith exception recognized in Lindquist does not apply here.”).