Cited by

Coolidge v. New Hampshire , 403 U.S. 443, 474 (1971)

Coolidge v. New Hampshire , 403 U.S. 443, 454-55, 474 (1971)

Cf. State v. Ortega , - 54 (Minn. 2009) (holding that officer had probable cause to search vehicle based on defendant’s nervous and evasive conduct and because defendant handed officer a small amount of marijuana) , aff’d

Coolidge v. New Hampshire, 403 U.S. 443, 474 (1971)

Coolidge v. New Hampshire, 403 U.S. 443, 454- 55 (1971)

4 “allows a criminal defendant to plead not guilty; waive all trial-related rights, including his or her right to a jury trial; stipulate to the state’s evidence in a trial to the court; and then appeal a dispositive pretrial ruling”); (stating that when a defendant stipulates to the state’s e vidence under what is now rule 26.01, subd.

Coolidge v. New Hampshire, 403 U.S. 443, 474 (1971)

Under Askerooth, to “search or seize, there must be an individualized, articulable, and reasonable suspicion of wrongdoing.”

“A person may constructively possess contraband jointl y with another person.” State v. 10 Ortega

-50 (Minn. 2009) (citing State v. Robb , ).

Probable cause to arrest exists when the objective facts are such that “a person of ordinary care and prudence, viewing the totality of the circumstances objectively, would entertain an honest and stro ng suspicion that a specific individual has committed a crime.” State v. Ortega , (emphasis omitted); -95 (Minn. 1997).

Pennsylvania v. Mimms , 434 U.S. 106, 109-12, 98 S. Ct. 330 , 332-34 (1977)

Appellate courts “may independently review facts that are not in dispute and determine, as a matter of law, whether the evidence need be suppressed.” (quotation omitted).

6 When reviewing a suppression order, we examine the district court’s factual findings for clear error, and defer to the district court’s credibility determinations, State v. Dickerson

n.2 (Minn. 2009), which clarified that the odor of marijuana is insufficient to justify a search incident to arrest unless the trooper can discern from the odor that the person possesses a criminal amount of marijuana, does not apply to the motor-vehicle exception to the search -warrant requirement.

4, appellate “rev iew is further limited to the pretrial order that denied [the appellant]’s motion to suppress.”

pening the door because the scope of a n investigatory seizure may include a limited search for weapons for the purpose of ensuring officer safety, see Askerooth, d at 370-71; State v. Alesso , , and an officer ma y ask a person to step out of a vehicle to allow such a search, see State v. Ortega , , 152 (Minn. 2009); State v. Krenik , , 184 (Minn. App. 2009), review denied (Minn. Jan.

“A person may constructively possess contraband jointly with another person.” State v. Ortega

“When reviewing a district court’s pretrial order on a motion to suppress evidence, we review the district court’s factual findings under a clearly erroneous standard and the district court’s legal determinations de novo.” (quotation omitted).

(“A person may constructively possess contraband jointly with another person.”).

Because appella nt stipulated to the prosecution’s evidence pursuant to rule 26.01, subdivision 4, “our review is further limited to the pretrial order that denied [appellant’s] motion to suppress.”