The Minnesota Supreme Court reinstated the dismissal of drug charges filed against a Faribault woman after she was mistakenly arrested on a no-longer-active warrant.
The top state court’s ruling reverses a Minnesota Court of Appeals ruling exactly one year prior and came almost exactly three years after the disputed arrest and search.
At issue is whether the search that found drugs on Rebecca Julie Malecha was unconstitutional, and if it was, whether the search qualified for a legal exception to the standard that illegally obtained evidence must be thrown out.
A Rice County judge decided it must be thrown out. A divided Court of Appeals ruled the exception applied. And finally on Tuesday, the Supreme Court sided with the county judge.
“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,” the Supreme Court ruling states.
Faribault police officers responded to a suspicious person report on March 7, 2021 and arrested Malecha because they believed she there was a court-issued warrant out for her arrest. Inside her backpack officers allegedly found multiple baggies of methamphetamine.
It turned out that the warrant was no longer active but had not been removed from law enforcement databases police due to a court clerical error.
The Rice County Attorney’s Office charged Malecha with felony drug sales and possession. Rice County Judge Jeffrey Johnson dismissed the case after finding the search of her backpack was unconstitutional and did not qualify for the “good faith exception.”
That exception comes from a U.S. Supreme Court ruling that if police acted “in objective good faith or their transgressions have been minor,” unlawfully obtained evidence may not need to be thrown out.
Prosecutors appealed and the Minnesota Court of Appeals overturned the dismissal. In a divided decision issued March 6, 2023, the majority of the appellate judges found that the search of Malecha’s backpack was either legal or the good faith exception applied because the officers had no way of knowing that the warrant had been rescinded.
The minority dissenting appellate judges argued the exception only applies in Minnesota when police conduct a search they believe is allowed by an appellate court precedent.
The Supreme Court ruling notes that there is no precedent in Minnesota to allow evidence obtained as the result of a clerical error.
The justices then weighed whether they should set such a precedent based on the Rice County case.
They found that the objective of excluding unlawfully obtained evidence is to deter “unlawful government conduct,” and that includes court employees.
“Applying the exclusionary rule here establishes that court employees, not only law enforcement officers, are held to account for errors that result in constitutional violations,” the ruling states. “Imposing the sanction of exclusion here promotes the public perception of fairness in the judicial process, particularly as illegally obtained evidence would otherwise be admitted by the same court system whose personnel caused the error that led to the unlawful search or seizure.”
The ruling also contends that excluding the evidence incentivizes court employees to “exercise better judgment, act with greater diligence, and implement improved policies to avoid the costs associated with such errors.”
And the ruling concludes: “The benefits of excluding the illegally obtained evidence here outweigh the costs. Therefore, we hold that under the Minnesota Constitution, the good-faith exception to the exclusionary rule does not extend to a search and arrest based on a quashed warrant that appears active to law enforcement because of a clerical error of court administration.”
But the ruling notes that it does not preclude the Supreme Court from expanding the good faith exception to apply to different circumstances.
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