State of Minnesota v. Dontrell Dyna Flowers

Summary

The Minnesota Supreme Court reviewed Dontrell Dyna Flowers's conviction for being a prohibited person in possession of a firearm. The court addressed the warrantless vehicle search, impeachment with a prior conviction, an officer's improper testimony that the firearm was stolen, and the district court's supplemental jury instruction on knowledge and possession. The court reversed the conviction, concluding that the warrantless search was not justified under the automobile or Terry exceptions and addressing the remaining issues.

Holdings

1. The State failed to establish probable cause to search the vehicle under the automobile exception. Flowers's furtive movements and delayed stop, without additional facts such as knowledge of a criminal record, a tip, or observed evidence of contraband, did not establish probable cause.
2. Although Flowers's movements gave officers reasonable suspicion of criminal activity and a reasonable belief that he might be armed and dangerous, the officers exceeded the permissible scope of a Terry search by returning to the vehicle and conducting another search after searching Flowers, conducting a protective vehicle search, and completing a dog sniff, without new specific and articulable facts.
3. The district court erred by failing to make a record showing that it considered and weighed the Jones factors before permitting impeachment with the prior conviction. Because the case was being reversed and remanded on other grounds, the court did not independently decide whether the error was harmless or whether the conviction was otherwise admissible.
4. The supplemental instruction was erroneous because it stated that knowledge may be inferred from the firearm's presence in a place under Flowers's exclusive control without adequately informing the jury that the inference was permissive and need not be drawn.

Questions Presented

1. Whether the warrantless search of the vehicle was justified under the automobile exception or the Terry protective-search exception.
2. Whether the district court erred by allowing the State to impeach Flowers with a prior conviction without making a record that it considered the Jones factors.
3. Whether the district court abused its discretion by denying a mistrial after an officer testified that the firearm was stolen.
4. Whether the district court's supplemental jury instruction improperly permitted an inference of knowing possession from the firearm's location in an area under Flowers' exclusive control.

Disposition

reversed_and_remanded