Cited by

Opinions in Minnesota that cite State v. Lemert, 843 N.W.2d 227.

82 citing documents.

  • State of Minnesota v. Rahma Abukar Abdi Minn. Ct. App. 2026
  • Melissa Ann Lorsung v. Commissioner of Public Safety Minn. 2026
  • Melissa Ann Lorsung v. Commissioner of Public Safety Minn. 2026
    Rather, we assess reasonableness through “an objective examination of the totality of the circumstances.” d 227, 230 (Minn. 2014).
  • State of Minnesota v. Michael Leroy Smalley, Jr. Minn. Ct. App. 2026
    “We evaluate whether a reasonable, articulable suspicion exists from the perspective of a trained police officer, who may make ‘inferences and deductions that might well elude an untrained person.”’ (quoting United States v. Cortez, 449 U.S. 411, 418 (1981)).
  • State of Minnesota v. Michael Patrick Daly Minn. Ct. App. 2026
  • State of Minnesota v. Michael Patrick Daly Minn. Ct. App. 2026
    (“Presence in a known drug house is a relevant, but not conclusive, factor” in reasonable-suspicion analysis); (concluding officer’s knowledge of defendant’s ties to drug-trafficking activities provided reasonable suspicion that defendant was armed and dangerous).
  • State of Minnesota, Respondent, vs. Noel Cortez, Appellant Minn. Ct. App. 2025
  • State of Minnesota, Respondent, vs. Noel Cortez, Appellant Minn. Ct. App. 2025
    second basis for suspecting criminal drug activity was the car’s “short turnaround trip to the metro area,” which “stood out” to the deputy because “[a] lot of narcotics that come up to [that] area are from the metro.” We are mindful that reasonable suspicion must be evaluated from the perspective of a trained police officer, whose inferences may “elude an untrained person.” (quotation omitted).
  • State of Minnesota v. Jeremy Douglas Brandt Minn. Ct. App. 2025
    Whether officers have reasonable, articulable suspicion to conduct a pat-frisk is reviewed “from the perspective of a trained police officer, who may make inferences and deductions that might well elude an untrained person.’” (quotation omitted).
  • In the Matter of the Welfare of: C.T.B. Minn. 2025
  • In the Matter of the Welfare of: C.T.B. Minn. 2025
    The reasonableness of an officer’s suspicions is judged by “an objective examination of the totality of the circumstances.”
  • State of Minnesota v. Andre Lorenzo Dee Minn. Ct. App. 2025
    The legality of a warrantless frisk for weapons “depends on an objective examination of the totality of the circumstances.”
  • State of Minnesota v. Donald Ray Shellito Minn. Ct. App. 2024
    And we consider reasonable suspicion from the perspective of a trained law-enforcement officer, whose inferences may “elude an untrained person.” (quoting United States v. Cortez, 449 U.S. 411, 418 (1981)).
  • State of Minnesota v. Darius Ahmadd Olson-Baker Minn. Ct. App. 2024
    is generally unreasonable unless it falls within an exception to the Fourth Amendment’s warrant requirement.”
  • State of Minnesota v. Dakota Lynn Cary Minn. Ct. App. 2024
    (concluding officer’s knowledge of defendant’s ties to drug-trafficking activities provided reasonable suspicion that defendant was armed).
  • State of Minnesota v. Jason Michael Randall Minn. Ct. App. 2024
    When evaluating reasonable suspicion, we do so from the perspective of a trained police officer, whose inferences may “elude an untrained person.” (quotation omitted).
  • State of Minnesota v. Cortez Drenele Williams Minn. Ct. App. 2023
    “The legality of a pat search depends on an objective examination of the totality of the circumstances.”
  • In the Matter of the Welfare of: C. T. B Minn. Ct. App. 2023
    When determining whether an officer reasonably suspected criminal activity and reasonably believe d a person might have been armed and dangerous , “our task is to determine whether, under the totality of the circumstances at the inception of the pat search, the officers had a reasonable, articulable suspicion that [defendant] might have been armed and dangerous.”
  • State of Minnesota v. Michael James Swanson Minn. Ct. App. 2023
    Although appellate courts frequently consider the actually articulated rationale that the seizing officer relied on for the stop, see, the more accurately described objective test is “whether a reasonable, articulable suspicion exists from the perspective of a trained police officer.” (emphasis added).
  • State of Minnesota v. Imagine Tera Sade Majors Minn. Ct. App. 2023
  • State of Minnesota v. Jonathan Gabriel Hernandez Silva Minn. Ct. App. 2023
    In doing so, the district court discussed caselaw concerning unlawful searches, and Minnesota v. Dickerson, 508 U.S. 366, 373 (1993).
  • State of Minnesota, Minn. 2023
    State v. Lemert , d 227, 232–33 (Minn. 2014) (quoting Ohio v. Robinette, 519 U.S. 33, 39 (1996)).
  • State of Minnesota v. Anthony Wayne LaPointe Minn. Ct. App. 2023
    We evaluate whether 6 reasonable suspicion exists from the perspective of a trained police officer, whose inferences may “elude an untrained person.” (quotation omitted).
  • State of Minnesota v. Ramiro Cruz-Pineda Minn. Ct. App. 2022
    Importantly, we consider reasonable suspicion from the perspective of a trained police 7 officer, whose inferences may “elude an untrained person.” State v. Lemert , (quoting United States v. Cortez , 449 U.S. 411, 418 (1981)).
  • State of Minnesota v. Preston Scott Sharlow Minn. Ct. App. 2022
    A proper reasonableness analysis under the Fourth Amendment instead considers whether the “officer has a particularized and objective basis for suspecting legal wrongdoing” as derived from the totality of the circumstances, (emphasis added) (quotations omitted), not whether the acting officer actually relied on that objective basis.
  • State of Minnesota v. Leland Wayne Thompson Minn. Ct. App. 2022
    A proper reasonableness analysis under the Fourth Amendment considers “whether the detaining officer has a particularized and objective basis for suspecting legal wrongdoing” as derived from the totality of the circumstances, (quotation omitted), not whether the detaining officer actually relied on that objective basis.
  • State of Minnesota v. Tomond Romell Grissom Minn. Ct. App. 2022
    “The legality of a pat search depends on an objective examin ation of the totality of the circumstances.”
  • R e s p o n d e n t , Minn. 2021
    Askerooth, d at 368 (addressing the State’s argument that officer safety concerns made the expansion of a traffic stop reasonable, even though the officer “articulated no specific safety concerns during his testimony” because the “reasona bleness test is an objective test”); –31 (Minn. 2014) (stating that “the legality of a pat search” under Terry “depends on an objective ex amination of the totality of the circumstances,” rather than “the actual, subjective beliefs of the officer” (citation omi
  • State of Minnesota v. Nicholas Gage Carr Minn. Ct. App. 2021
    We 8 The state cites three cases to support its position that officer safety concerns permit a search in the absence of reasonable suspicion: State v. Lemert
  • State of Minnesota v. Ronnie Bila Shaka Minn. Ct. App. 2021
    Shaka does not challenge the formal search of the master bedroom that occurred after S.S.
  • State of Minnesota v. Kristoffer Marshall Anderson Minn. Ct. App. 2020
    “We evaluate whether a reasonable, articulable suspicion exists from the perspective of a trained police officer, who may make ‘inferences and deductions that might well elude an untrained person.’” State v. Lemert , (quoting United States v. Cortez, 449 U.S. 411, 418, 101 S. Ct. 690, 695 (1981)).
  • State of Minnesota v. Christian John Donnelly Minn. Ct. App. 2020
    “We evaluate whether a reasonable, articulable sus picion [to conduct a pat-frisk] exists from the perspective of a trained police officer, who may make ‘inferences and deductions that might well elude an untrained person.’” (quoting United States v. Cortez, 449 U.S. 411, 418, 101 S. Ct. 690, 695 (1981)).
  • State of Minnesota v. Irwin James Sam Minn. Ct. App. 2020
    We also note that the supreme court has recognized that a “substantial nexus exists between drug dealing and violence.” (citations omitted); see also State v. Ludtke , 3 (concluding frisk was justifiable where officer was alone on the highway with two people who possessed marijuana, one of whom was seen making a furtive movement in the back of the car).
  • Thomas Randal Schreyer v. Commissioner of Public Safety Minn. Ct. App. 2019
    And courts consid er this question “from the perspective of a trained police officer, who may make inferences and deductions that might well elude an untrained person.” State v. Lemert , (quotation omitted).
  • State of Minnesota, Minn. 2019
  • State of Minnesota v. Christopher Lee Antoine Brown Minn. Ct. App. 2019
    d 227, 231 (Minn. 2014) (citing Whren v. United States, 517 U.S. 806, 812, 116 S. Ct. 1769, 1774 (1996)).
  • State of Minnesota v. Gary Walter Granger Minn. Ct. App. 2018
    –13 (Minn. App. 2012) (holding state trooper had a reasonable, articulable suspicion of criminal activity sufficient to perform an investigatory stop of vehicle after license -plate check revealed outstanding arrest warrant for registered owner); (“We evaluate whether a reasonable, articulable suspicion exists .
  • State of Minnesota v. Xavier Richard Jamieson Minn. Ct. App. 2018
    “The legality of a pat search depends on an objective examination of the totality of the circumstances.”
  • State of Minnesota v. Chakotay Bobbie Johnson Minn. Ct. App. 2017
  • State of Minnesota v. Christopher Blane Hughes Minn. Ct. App. 2017
    12 State v. Lemert , (quo tations and citations omitted), aff’d
  • State of Minnesota v. Jamaul Anthony Brisco-Turner Minn. Ct. App. 2017
    “The protective pat search ‘must be strictly “limited to that which is necessary for the discovery of weapons which might be used to harm the officer or others nearby.”’” d 227, 230 ( Minn. 2014) (quoting Minnesota v. Dickerson , 508 U.S. 366, 373, 113 S. Ct. 2130, 2136 (1993) (quoting Terry, 392 U.S. at 26, 88 S. Ct. at 1882)).
  • State of Minnesota v. Gideon Wesseh Chea Minn. Ct. App. 2017
  • State of Minnesota v. Jovon Nathan Freshwater Minn. Ct. App. 2017
    Because “a substanti al nexus exists between drug dealing and violence,” it is reasonable for police “to believe a person may be armed and dangerous when the person is suspected of being involved in a drug transaction.” United States v. Bustos -Torres, 396 F.3d 935, 943 ( 8th Cir. 2005)
  • State of Minnesota v. Frank Irving Wiggins Minn. Ct. App. 2017
    This court considers the totality of the circumstances to determine “whether a reasonable, articulable suspicion exists from the perspective of a trained police officer, who may make inferences and deductions that might well elude an untrained person.” State v. Lemert , (quotation omitted) .
  • Justin Stephen Ries v. State of Minnesota 889 N.W.2d 308 Minn. Ct. App. 2016
  • Justin Stephen Ries v. State of Minnesota 889 N.W.2d 308 Minn. Ct. App. 2016
    A protective pat search of a person’s outer clothing is a recognized exception to the warrant requirement if “the officer has a reasonable, articulable suspicion that the person whom the officer has lawfully detained may be armed and dangerous.” (citing Terry v. Ohio, 392 U.S. 1, 26-27, 88 S. Ct. 1868, 1882-83 (1968)).
  • State of Minnesota v. Travis Richard Otto Minn. Ct. App. 2016
  • State of Minnesota v. Travis Richard Otto Minn. Ct. App. 2016
  • Roger William Kuehn v. Commissioner of Public Safety Minn. Ct. App. 2016
  • Roger William Kuehn v. Commissioner of Public Safety Minn. Ct. App. 2016