Cited by

Opinions in Minnesota that cite State v. Olson, 634 N.W.2d 224.

42 citing documents.

State of Minnesota v. Michael Patrick Daly Minn. Ct. App. 2026
Distinguished State of Minnesota v. Michael Patrick Daly Minn. Ct. App. 2026
s] pickup,” and his contention that “the marijuana and methamphetamine law enforcement found were the fruit of that illegal conduct.” Evidence obtained through illegal police conduct is considered “the fruit of the poisonous tree” and may not be admitted unless the state proves the evidence was obtained “by means sufficiently distinguishable to be purged of the primary taint.” d 224, 229 (Minn. App. 2001) (quoting Wong Sun v. United States, 371 U.S. 471, 488 (1963)), rev. denied (Minn. Dec.
State of Minnesota, Appellant, Minn. Ct. App. 2025
(), rev. denied (Minn. Dec.
State of Minnesota v. Nicholas Norton Engel Minn. Ct. App. 2025
State of Minnesota v. Nicholas Norton Engel Minn. Ct. App. 2025
“Such evidence is considered ‘fruit of the poisonous tree.’” (quoting Wong Sun v. United States, 371 U.S. 471, 488 (1963)), rev. denied (Minn. Dec.
State of Minnesota, Respondent, Minn. Ct. App. 2024
(reasoning that an officer told the defendant “that he was ‘under arrest,’ handcuffed him, and began a pat - down search in anticipation of placing [defendant] in his squad car,” and that “a reasonable 14 person in [the defendant’s] circumstances would have believed that he was formally und
State of Minnesota v. Drew Douglas Wiskow Davis Minn. Ct. App. 2024
State of Minnesota v. Drew Douglas Wiskow Davis Minn. Ct. App. 2024
Temporal Proximity “A close temporal proximity favors exclusion.”
Distinguished State of Minnesota, Respondent, Minn. Ct. App. 2024
Evidence obtained through illegal law-enforcement conduct is considered “the fruit of the poisonous tree” and may not be admitted unless the state proves the evidence was obtained “by means sufficiently distinguishable to be purged of the primary taint.” (quoting Wong Sun v. United States , 371 U.S. 471, 488 (1963)), rev. denied (Minn. Dec.
State of Minnesota, Respondent, Minn. Ct. App. 2023
Reasonable suspicion must be based on specific, articulable facts that allow the officer to be able to articulate at the omnibus hearing that he or she had a particularized and objective basis for suspecting [a] person of criminal activity.” - discovered by exploiting previous illegal conduct” is inadmissible “fruit of the poisonous tree.” (quoting Wong Sun v. United States, 371 U.S. 471, 488 (1963)), rev. denied (Minn. Dec.
State of Minnesota, Respondent, Minn. Ct. App. 2023
State of Minnesota, Respondent, Minn. Ct. App. 2021
review denied (Minn. Dec.
State of Minnesota, Respondent, Minn. Ct. App. 2019
See Wong Sun v. United States , 371 U.S. 471, 487-88, 83 S. Ct. 407, 417 (1963); State v. Olson , review denied (Minn. Dec.
State of Minnesota, Respondent, Minn. Ct. App. 2019
It is well established that “evidence discovered by exploiting D-3 previous illegal conduct is inadmissible.” State v. Olson
Distinguished State of Minnesota, Respondent, Minn. Ct. App. 2018
It does not ap ply if the state shows “that the evidence was obtained ‘by means sufficiently distinguishable to be purged of the primary taint.’” (quoting Wong Sun v. United States, 371 U.S. 471, 488, 83 S. Ct. 407, 417 (1963)), review denied (Minn. Dec.
State of Minnesota, Appellant, Minn. Ct. App. 2018
hether the evidence is fruit of the poisonous tree, courts consider: “(1) the purpose and flagrancy of the mi sconduct; (2) the presence of intervening circumstances; (3) whether it is likely that the evidence would have been obtained in the absence of the illegality; and (4) the temporal proximity of the illegality and the evidence alleged to be the fruit of the illegality.” review denied (Minn. Dec.
State of Minnesota, Respondent, Minn. Ct. App. 2018
“[E]vidence discovered by exploiting previous illegal conduct is inadmissible” and is “considered fruit of the poisonous tree.” (quotation omitted) (citing Wong Sun v. United States , 371 U.S. 471, 488, 83 S. Ct. 407, 417 (1963)), review denied (Minn. Dec.
State of Minnesota, Appellant, Minn. Ct. App. 2018
(citations and quotation omitted), review denied (Minn. Dec.
State of Minnesota v. Leona Rose deLottinville 877 N.W.2d 199 Minn. Ct. App. 2016
State of Minnesota v. Leona Rose deLottinville 877 N.W.2d 199 Minn. Ct. App. 2016
“It is established that evidence discovered by exploiting previous illegal conduct is inadmissible.” (citing Wong Sun v. United States, 371 U.S. 471, 488, 83 S. Ct. 407, 417 (1963)), review denied (Minn. Dec.
Jason Richard Montonye v. Commissioner of Public Safety Minn. Ct. App. 2015
Jason Richard Montonye v. Commissioner of Public Safety Minn. Ct. App. 2015
The probable-cause standard is “an objective one that considers the totality of the circumstances.” review denied (Minn. Dec.
State of Minnesota v. Thomas James Mitchell Minn. Ct. App. 2015
State of Minnesota v. Thomas James Mitchell Minn. Ct. App. 2015
d 224, 229 (Minn. App. 2001) (“[E]vidence discovered by exploiting previous illegal [police] conduct is inadmissible.”), review denied (Minn. Dec.
Peter Alan Krech v. Commissioner of Public Safety Minn. Ct. App. 2015
Peter Alan Krech v. Commissioner of Public Safety Minn. Ct. App. 2015
“The probable-cause standard is an objective one that considers the totality of the circumstances.” review denied (Minn. Dec.
State of Minnesota v. Adam Alvarado Minn. Ct. App. 2015
State of Minnesota v. Ashley Shayia Lee, (A14-1503), State of Minnesota v. Tasheanna Yvonne Moore, (A14-1504). Minn. Ct. App. 2015
State of Minnesota v. Ashley Shayia Lee, (A14-1503), State of Minnesota v. Tasheanna Yvonne Moore, (A14-1504). Minn. Ct. App. 2015
(holding that, even though the arresting officer did not have probable cause for the initial arrest, the arrestee’s subsequent obstruction of process “purge[d] the taint of the initial illegality”), review denied (Minn. Dec.
State of Minnesota v. Adam Alvarado Minn. Ct. App. 2015
“The probable-cause standard is an objective one that considers the totality of the circumstances.” review denied (Minn. Dec.
State v. Barajas 817 N.W.2d 204 Minn. Ct. App. 2012
State v. Barajas 817 N.W.2d 204 Minn. Ct. App. 2012
United States v. Lakoskey, 462 F.3d 965, 975 (8th Cir.2006); accord State v. Weekes, 312 Minn. 1, 8-10 , -95 (1977) (recognizing this rule in *218 the context of an incriminating statement obtained during unlawful confinement); (citing Wong Sun v. United States, 371 U.S. 471, 488 , 83 S.Ct.
State v. Lussier 770 N.W.2d 581 Minn. Ct. App. 2009
State v. Lussier 770 N.W.2d 581 Minn. Ct. App. 2009
“The probable-cause standard is an objective one that considers the totality of the circumstances.” review denied (Minn. Dec.
In Re the Welfare of J.W.L. 732 N.W.2d 332 Minn. Ct. App. 2007
In Re the Welfare of J.W.L. 732 N.W.2d 332 Minn. Ct. App. 2007
“It is established that evidence discovered by exploiting previous illegal conduct is inadmissible.” (citing Wong Sun v. United States, 371 U.S. 471, 488 , 83 S.Ct.
State v. Johnson 689 N.W.2d 247 Minn. Ct. App. 2004
State v. Johnson 689 N.W.2d 247 Minn. Ct. App. 2004
“The probable-cause standard is an objective one that considers the totality of the circumstances.” review denied (Minn. Dec.
State v. Bergerson 659 N.W.2d 791 Minn. Ct. App. 2003
State v. Bergerson 659 N.W.2d 791 Minn. Ct. App. 2003
“[E]vi-dence discovered by exploiting previous illegal conduct is inadmissible.” (citing Wong Sun v. United States, 371 U.S. 471, 488 , 83 S.Ct.
State v. Mellett 642 N.W.2d 779 Minn. Ct. App. 2002
State v. Mellett 642 N.W.2d 779 Minn. Ct. App. 2002
See, (person under arrest and therefore in custody when handcuffed); (concluding that an officer telling suspect he was “under arrest” indicated custody), review denied (Minn. Dec.

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