On August 19, 2015, the Minnesota Supreme Court issued a potentially game-changing decision in State v. Lindquist. In a 4–3 decision, the Court held that the “good-faith exception” to the exclusionary rule applied in a driving while intoxicated (DWI) prosecution. While the majority opinion, written by Justice Anderson, clearly indicated this is a very narrow exception to the exclusionary rule and implied that it is not likely to frequently resurface, the dissent vigorously disagreed. The dissent argued that the good-faith exception should not apply in this case and voiced concerns about expansion of the rule into areas the Court has declined to extend itself previously. While the good-faith exception applied in this case, it may not apply in others.
The facts of the case are not very complicated. In February of 2011, officers received an emergency call that a person was injured in a single-car accident. A witness told police one of the occupants of the car suffered an injury and both fled. Officers learned that the car was owned by Bonnie Lindquist and her husband. Police went to their home to investigate and found the Lindquists hiding in a closet. Mr. Lindquist was suffering from a head injury.
The police investigation determined that Bonnie Lindquist (hereinafter “Lindquist”) was the driver and crashed the car. The investigating officers observed Lindquist to be slurring her speech, had bloodshot eyes, and was unsteady on her feet. She failed field sobriety tests and then refused a preliminary breath test. Consequently, police placed her in custody and brought her to the hospital for a blood draw consistent with established police procedure. Her blood was taken without a warrant and analysis showed that even two hours post-crash her blood alcohol concentration (BAC) was 0.23. Ultimately, Lindquist was convicted by a jury of third-degree DWI. She appealed to the Minnesota appeals courts and lost that appeal.
Nine days after the appeals court affirmed her conviction, Lindquist had a glimmer of hope. The United States Supreme Court ruled that single-exigency blood draws without a warrant were unlawful searches and violated the protections guaranteed by the Fourth and Fourteenth Amendments to the United States Constitution. This ruling overturned previous Minnesota cases allowing single-exigency blood draws on the simple basis that alcohol levels in blood dissipate over time. The U.S. Supreme Court, as a matter of constitutional law, ruled that the evidence must be reviewed in the totality of the circumstances by a judge before ruling on the admissibility of the blood draw without a warrant. Thus, the officers violated Lindquist’s rights by taking her blood without a warrant. Lindquist appealed again.
On rehearing, the majority of the Minnesota Supreme Court justices ruled against Lindquist. The majority concluded that because the officers were following established precedent at the time of the blood draw and followed it in good faith there was no reason to suppress the blood evidence even though it was obtained in violation of Lindquist’s constitutional rights. This “good faith exception,” the majority reasoned, was a narrow exception to the exclusionary rule and would only be used in situations essentially identical to Lindquist’s.
A defiant dissent argued otherwise. The dissenting judges argued that because Lindquist’s rights were violated, Minnesota law required suppression of the evidence. The dissent forcefully argued that Minnesota’s constitutional protections are greater than those conferred by the United States Constitution and those greater protections required suppression even if the officers were acting in good faith. The dissent also voiced significant concern about the good-faith exception being accepted by the court in circumstances where the police have violated people’s rights, such as relying on a facially valid search warrant.