State of Minnesota v. Bonnie Ann Lindquist

Summary

The Minnesota Supreme Court held that a defendant may raise a constitutional challenge based on an intervening change in law when the objection would previously have been futile. The court adopted the good-faith exception to the exclusionary rule for evidence obtained through objectively reasonable reliance on binding appellate precedent. It affirmed Bonnie Ann Lindquist’s DWI conviction because the officer reasonably relied on then-binding precedent permitting the warrantless blood draw.

Holdings

1. A criminal defendant does not forfeit a constitutional challenge that was not asserted in the district court when an intervening Supreme Court decision creates a new rule of constitutional criminal procedure and the challenge would have been futile under controlling precedent.
2. The exclusionary rule does not apply to violations of the Fourth Amendment or Article I, Section 10, of the Minnesota Constitution when law enforcement acts in objectively reasonable reliance on binding appellate precedent that specifically authorizes the challenged police practice.
3. The Minnesota exception adopted in this case is limited to objectively reasonable reliance on binding appellate precedent that specifically authorizes the police conduct; it does not extend to persuasive precedent, unsettled law, or other good-faith exceptions not expressly adopted.
4. The blood-test results were admissible because the officer acted in objectively reasonable reliance on then-binding Minnesota precedent holding that alcohol dissipation created a single-factor exigency supporting a warrantless blood draw.

Questions Presented

1. Whether Lindquist forfeited her constitutional challenge to the warrantless blood draw by failing to raise it in the district court and before the first appeal, when Missouri v. McNeely later changed the governing law.
2. Whether Minnesota should adopt the Davis v. United States good-faith exception to the exclusionary rule for evidence obtained in objectively reasonable reliance on binding appellate precedent.
3. Whether the Davis good-faith exception applies to the results of Lindquist's warrantless blood draw.
4. Whether the warrantless blood draw was constitutional under McNeely.

Disposition

affirmed