Cited by

d 243, 250 (Minn. 2003) (citing Katz v. United States, 389 U.S. 347, 357 (1967)).

“If the state can establish by a preponderance of the evidence that the fruits of a challenged search ‘ultimately or inevitably would have been discovered by lawful means,’ then the seized evidence is admissible even if the search violated the warrant requirement.” d 243, 254 (Minn. 2003) (quoting Nix v. Williams, 467 U.S. 431, 444 (1984)).

(citing Katz v. United States, 389 U.S. 347, 357 (1967)).

Under the Fourth Amendment to the United States Constitution and article I, section 10 of the Minnesota Constitution, “[w]arrantless searches are presumptively unreasonable unless one of ‘a few specifically established and well-delineated exceptions’ 11 applies.” d 243, 250 (Minn. 2003) (quoting Katz v. United States, 389 U.S. 347, 357 (1967)).

In addition, the district court received several exhibits: Deputy Z.S.’s body-worn camera footage; Robinson’s booking 1 (explaining that the district court can admit evidence obtained as a result of an unlawful search or seizure “[i]f the state can establish by a preponderance of the evidence that the fruits of a challenged search ultimately or inevitably would have been discovered by lawful means” (quotation omit

4 The inevitable-discovery exception provides that evidence seized in a warrantless search may be admissible if the state proves by a preponderance of evidence that the evidence “ultimately or inevitably would have been discovered by lawful means.”

“The state bears the burden of establishing the applicability of an exception.”

For the doctrine to apply, there can be “no speculative elements[.]” (quotation omitted).

The inevitable-discovery doctrine provides that, “[i]f the state can establish by a preponderance of the evidence that the fruits of a challenged search ‘ultimately or inevitably would have been discovered by lawful means,’ then the seized evidence is admissible even if the search violated the warrant requirement.” (quoting Nix v. Williams, 467 U.S. 431, 4 44 (1984)).

One such exception is the inevitable-discovery doctrine, which permits a court to admit evidence obtained as a result of an unlawful search or seizure “[i]f the state can establish by a preponderance of the evidence that the fruits of a challenged search ultimately or inevitably would have been discovered by lawful means.” (quotation omitted).

“Warrantless searches are presumptively unreasonable unless one of ‘a few specifically established and well-delineated exceptions’ applies.” (quoting Katz v. United States, 389 U.S. 347, 357 (1967)).

even if the search violated the warrant requirement.” (quotation omitted).

Missouri v. McNeely, 569 U.S. 141, 148-49 (2013); -99 (Minn. 2012)

( stating that “searches based on honest, reasonable mistakes of fact are unobjectionable under the Fourth Amendment”); d 866, 868 (Minn. 1981); City of St.

Inevitable-Discovery Exception Under the inevitable-discovery exception, “[i]f the state can establish by a preponderance of the evidence that the fruits of a challenged search ultimately or inevitably would have been discovered by lawful means, then the seized evidence is admissible even if the search violated the warrant requirement.” (quotation omitted).

could have made any determination about the status or nature of Fohrenkam’s 5 See, 631 (Minn. 2018) (pat-frisk, community- caretaker, and exigent-circumstances exceptions); (automobile exception); (search incident to lawful arrest); -54 (Minn. 2003) (actual-authority-to-consent, apparent-authority-to-consent, plain-view, and inevitable- discovery exceptions).

A warrantless search is “presumptively unreasonable unless one of a few specifically established and well-delineated exceptions applies.” (quotation omitted).

“Warrantless searches are presumptively unreasonable unless one of a few specifically established and well-delineated exceptions applies.” (quotation omitted).

“Warrantless searches are presumptively unreasonable unless one of ‘a few specifically established and well-delineated exceptions’ applies.” (quoting Katz v. United States, 389 U.S. 347, 357 (1967)).

(quoting Nix v. Williams, 476 U.S. 431, 444 (1984)).

Warrantless searches and seizures are unreasonable under both the state and federal constitutions unless a recognized warrant exception applies, Coolidge v. New Hampshire , 403 U.S. 443, 454- 55 (1971); and the state must show that such an exception applies

“The state bears the burden of establishing the applicability of an exception [to the warrant requirement].” State v. Licari

See State v. Licari , (explaining the inevitable discovery doctrine) .

But “searches based on honest, reasonable mistakes of fact are unobjectionable under the Fourth Amendment.” (contrasting officers’ unobjectionable mistakes of fact with their mistakes of law, which “cannot be reasonable”).

Hill v. California, 401 U.S. 797, 802-04 (1971) (upholding an arrest where the police officers had probable cause to arrest a suspect and reasonably mist ook another for the suspect in good faith); ( noting that “honest, reasonable mistakes of fact are unobjectionable under the Fourth Amendment”).

d 243, 250 (Minn. 2003).

We note that even if the DVS records in this case were incorrect, it does not necessarily follow that the resulting stop was invalid because “honest, reasonable mistakes 6 of fact are unobjectionable under the Fourth Amendment.” d 243, 254 (Minn. 2003).

ack of research, failure to specify issues or to cite relevant authorities.” n.7 (Minn. 1990) (quotation o mitted) (considering the law of “severance” and “partial invalidity” in the Fourth Amendment context , despite neither party discussing their applicability, but concluding the doctrines were not “novel or questionable”); (applying the inevitable-discovery doctrine); -16 (Minn. 1979) (applying the independent-source doctrine).

d 243, 250 (Minn. 2003).