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would make a reasonably prudent person think that a search would reveal contraband or evidence of a crime.” Florida v. Harris, 568 U.S. 237, 248 (2013); see also 2 In reviewing the totality of the circumstances, we do not consider Kyle’s refusal to consent to a search because “refusal of consent cannot be considered in establishing probable cause for a search.”

Terry v. Ohio, 392 U.S. 1, 12-13 (1968)

Although the threshold for reasonable suspicion is “not high,” (quotation omitted), it requires “more than an unarticulated hunch.” -26 (Minn. 1989) (quotation omitted).

Here, the deputy testified at the suppression hearing to “specific, articulable facts” that provided him with “a particularized and objective basis for suspecting [Wurzbacher] of criminal activity.” State v. Diede , -43 (Minn. 2011) (quotations omitted).

d 768, 771 (Minn. 2016) (“We review de novo a trial court’s determination of probable cause as it relates to a warrantless search.”).

Indeed, Middlebrook argued in the district court proceedings that the officers did not have 4 A Terry stop “allows a police officer to stop and temporarily seize a person to investigate that person for criminal wrongdoing if the officer reasonably suspects that person of criminal activity.” (quotation omitted) (citing Terry v. Ohio, 392 U.S. 1 (1968)).

d 124, 132 (Minn. 2024).

d 396, 410 (Minn. App. 2025) (“Generally, evidence obtained through an unlawful expansion of the scope of a vehicle stop must be suppressed.”).

“The reasonable-suspicion standard is not high.” ().

Because the question of whether a consent to search is voluntary or stemmed from duress or coercion is one of fact, the “clearly erroneous standard controls our review of a district court’s finding of voluntary consent.” (quotation omitted).

“[W]arrantless searches are presumptively unreasonable unless one of a few specifically established and well-delineated exceptions applies.” (quotations omitted).

We overrule d 752 (Minn. 1998), as clearly in conflict with the inevitable discovery rule articulated in Nix v. Williams, 467 U.S. 431 (1984)

We have also often remarked that the threshold for reasonable suspicion “is ‘not high.’ ” d 836, 843 (Minn. 2011) ().

Whether consent is voluntary is a question of fact that we review for clear error, and here the district court found that Smith “freely and voluntarily consented to the officers entering his car and retrieving his phone.” The record supports the finding.

(citing Terry v. Ohio, 392 U.S 1 (1968)).

Finally, the state contends we should affirm pursuant to the inevitable discovery doctrine.3 Under the inevitable discovery doctrine, illegally seized evidence is admissible if the state can establish that the fruits of the unconstitutional search or seizure “inevitably would have been discovered by lawful means[.]” (quotation omitted).

d 836, 849 (Minn. 2011).

5 Berkemer, 468 U.S. at 439-40; (citing Terry v. Ohio, 392 U.S. 1, 29 (1968)); -43 (Minn. 2011).

-43 (Minn. 2011) (quotation omitted).

- 44 (Minn. 2011) (concluding that factual circumstances that “did not yet exist when Diede was seized” could not serve as objective basis to justify seizure).

that he or she had a particularized and objective basis for suspecting the seized person of criminal activity.” -43 (Minn. 2011) (quotation omitted).

“Findings of fact are clearly erroneous if, on the entire evidence, [appellate courts] are left with the definite and firm conviction that a mistake occurred.” -47 (Minn. 2011).

Under the principles articulated in Terry v. Ohio, 392 U.S. 1 (1968), the police may temporarily detain a -43 (Minn. 2011).

The standard for reasonable suspicion to conduct an investigatory traffic stop is not high, but it does require “at least a minimal level of objective justification for making the stop.” (quotation omitted).

-43 (Minn. 2011) (citing Terry v. Ohio, 392 U.S. 1 (1968)).