Fourth Amendment warrant requirement (Minnesota) · Go Syfert
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Fourth Amendment warrant requirement in Minnesota

9 Minnesota opinions name it 2 courts 1986–2025 1 in the last five years

The cases below were cited by Minnesota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
In Re Welfare of G. (NMN) M.green
minn · 1997 · cited in 2 Minnesota opinions naming this issue, 2009–2025
2 sentences

2025See, e.g., Ortega, 770 N.W.2d at 149 n.2 (“[A]lthough ‘probable cause to arrest’ satisfies the search-incident-to-arrest exception to the Fourth Amendment warrant requirement when an arrest is made, ‘probable cause to search’ does not necessarily trigger an exception to the warrant requirement or lead to the conclusion that the search was otherwise reasonable.”); In re Welfare of G.M., 560 N.W.2d 687, 695 (Minn. 1997) (“[P]robable cause to search and probable cause to arrest are distinct. . . .

2009See In Re Welfare of G.M., 560 N.W.2d 687, 692 (Minn.1997) (explaining that “[ujnless one of the well-delineated exceptions is applicable, police need both probable cause and a warrant before they can seize an item from a person”). 3 .

22
Missouri v. McNeelygreen
scotus · 2013 · cited in 2 Minnesota opinions naming this issue, 2016–2016
2 sentences

2016McNeely, 133 S. Ct. at 1558 .

2016McNeely, 133 S. Ct. at 1558 (stating that the warrant requirement “applies to the type of search at issue in this case, which involved a compelled physical intrusion beneath McNeely’s skin and into his veins . . . .”); see also State v. Trahan, 870 N.W.2d 396, 401 (Minn. App. 2015) (“A blood draw is undeniably intrusive . . . .”), review granted (Minn. Nov. 25, 2015).

12
Chambers v. Maroneygreen
scotus · 1970 · cited in 1 Minnesota opinions naming this issue, 2025–2025
1 sentence

2025Whereas probable cause to search requires police to have a reasonable belief that incriminating evidence is in a certain location, probable cause to arrest requires police to have a reasonable belief that a certain person has committed a crime.” (citations omitted)); see also Chambers v. Maroney, 399 U.S. 42, 49 (1970) (“[T]he search of an auto[mobile based] on probable cause proceeds on a theory wholly different from that justifying the search incident to an arrest[.]”). 16 evidence of only a noncriminal amount of marijuana.” Douglas, 12 N.W.3d at 767 (Ross, J., dissenting).

11
State v. Ortegagreen
minn · 2009 · cited in 1 Minnesota opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., Ortega, 770 N.W.2d at 149 n.2 (“[A]lthough ‘probable cause to arrest’ satisfies the search-incident-to-arrest exception to the Fourth Amendment warrant requirement when an arrest is made, ‘probable cause to search’ does not necessarily trigger an exception to the warrant requirement or lead to the conclusion that the search was otherwise reasonable.”); In re Welfare of G.M., 560 N.W.2d 687, 695 (Minn. 1997) (“[P]robable cause to search and probable cause to arrest are distinct. . . .

11
United States v. Webstergreen
ca8 · 2010 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016See United States v. Webster, 625 F.3d 439, 445 (8th Cir. 2010) (“Warrantless searches need only be justified by one exception to the Fourth Amendment warrant requirement . . . .”).

11
State of Minnesota v. Todd Eugene Trahangreen
minnctapp · 2015 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016McNeely, 133 S. Ct. at 1558 (stating that the warrant requirement “applies to the type of search at issue in this case, which involved a compelled physical intrusion beneath McNeely’s skin and into his veins . . . .”); see also State v. Trahan, 870 N.W.2d 396, 401 (Minn. App. 2015) (“A blood draw is undeniably intrusive . . . .”), review granted (Minn. Nov. 25, 2015).

11
Birchfield v. N. Dakota. William Robert Bernardgreen
scotus · 2016 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016Moreover, the Supreme Court of the United States recently affirmed Bernard, holding 11 that “the Fourth Amendment permits warrantless breath tests incident to arrests for drunk driving.” Birchfield, 136 S. Ct. at 2165, 2184 .

11
State v. Johnsongreen
minnctapp · 2004 · cited in 1 Minnesota opinions naming this issue, 2014–2014
1 sentence

2014State v. Johnson, 689 N.W.2d 247, 251 (Minn. App. 2004).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
State v. Fulford green
minn · 1971
2 sentences

2007The district court also cited State v. Fulford, 290 Minn. 236 , 187 N.W.2d 270 (1971), for the principle that when police are where they have a legal right to be, they may photograph the area that is in plain view.

2007The district court also cited State v. Fulford, 290 Minn. 236 , 187 N.W.2d 270 (1971), for the principle that when police are where they have a legal right to be, they may photograph the area that is in plain view.

12007–2007
Wong Sun v. United States green
scotus · 1963
2 sentences

1992Wong Sun v. United States, 371 U.S. 471, 484 , 83 S.Ct. 407, 415-16 , 9 L.Ed.2d 441 (1963): The trial court and the dissenting justices of this court would allow the seized evidence to be admissible under a "plain feel" exception to the fourth amendment warrant requirement.

1992Wong Sun v. United States, 371 U.S. 471, 484 , 83 S.Ct. 407, 415-16 , 9 L.Ed.2d 441 (1963): The trial court and the dissenting justices of this court would allow the seized evidence to be admissible under a "plain feel" exception to the fourth amendment warrant requirement.

11992–1992
Terry v. Ohio green
scotus · 1968
2 sentences

1992The trial court denied the defendant's motion to suppress the evidence, ruling that the stop was justified under Terry v. Ohio, 392 U.S. 1 , 88 S.Ct. 1868 , 20 L.Ed.2d 889 (1968), and that seizure of the cocaine was justified under a "plain feel" exception to the fourth amendment warrant requirement.

1992The trial court denied the defendant's motion to suppress the evidence, ruling that the stop was justified under Terry v. Ohio, 392 U.S. 1 , 88 S.Ct. 1868 , 20 L.Ed.2d 889 (1968), and that seizure of the cocaine was justified under a "plain feel" exception to the fourth amendment warrant requirement.

11992–1992
Lewis L. Wayne v. United States green
cadc · 1963
1 sentence

1986The first formal statement of the doctrine appeared in Wayne v. United States, 318 F.2d 205 (D.C.Cir.1963), where then Judge Warren Burger stated: a warrant is not required to break down a door to enter a burning home to rescue occupants or extinguish a fire, to prevent a shooting or to bring emergency aid to an injured person.

11986–1986

Statutes the citing opinions construe

MN § Minn. Stat. § 480A.08 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

OH 276 (1976–2025) TX 99 (1982–2026) ID 33 (1982–2026) TN 27 (1981–2026) MO 24 (1970–2025) CA 24 (1974–2024) WA 22 (1975–2022) PA 19 (1973–2025) VA 19 (1982–2026) IN 18 (1981–2025) MD 16 (1984–2022) IL 16 (1979–2025) WI 15 (1993–2024) NJ 13 (1978–2024) FL 12 (1979–2025) MI 11 (1974–2024) NY 10 (1980–2021) MS 10 (1981–2015) IA 10 (1978–2021) MN 9 (1986–2025) AZ 8 (1978–2026) DC 8 (1981–2025) AL 7 (1979–1994) OR 7 (1982–2016) UT 7 (1985–2024) CO 6 (1983–2024) SC 6 (1980–2020) OK 5 (1990–2016) ND 4 (2008–2017) NC 4 (2015–2018) WY 4 (1983–2001) SD 4 (1978–2014) MA 4 (1982–1999) CT 4 (1980–2017) KS 3 (2020–2024) HI 3 (1981–2015) RI 3 (1978–2014) NV 3 (1981–2022) MT 3 (1982–2021) NM 2 (1994–2004) ME 2 (2009–2010) LA 2 (1986–1987) WV 2 (1989–2023)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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