Cited by

Opinions in Minnesota that cite State v. Hanson, 504 N.W.2d 219.

37 citing documents.

State of Minnesota v. Marcellus Anthony Jones Minn. Ct. App. 2026
(explaining that a police officer’s use of their emergency lights usually signals that they are seizing a person for an investigatory stop).
State of Minnesota v. Wendy Sue Whitcomb Minn. Ct. App. 2025
State of Minnesota v. Wendy Sue Whitcomb Minn. Ct. App. 2025
(“A reasonable person would have assumed that the officer was not doing anything other than checking to see what was going on and to offer help if needed.”).
State of Minnesota v. Lisa Marie Hellerud-Schuth Minn. Ct. App. 2024
(holding that the standard is always whether “the conduct of the police would communicate to a reasonable person in the defendant’s physical circumstances an attempt by the police to capture or seize” and that when an officer approaches to offer help, a reasonable person would not feel seized).
State of Minnesota v. Sarah Jean Mona Dubinsky Minn. Ct. App. 2023
State of Minnesota v. Sarah Jean Mona Dubinsky Minn. Ct. App. 2023
(discussing a similar question in the context of emergency vehicle lights).
State of Minnesota v. Jose Alarcon Minn. Ct. App. 2023
To decide whether there was a seizure, a court must consider “whether, looking at all of the facts, the conduct of the police would communicate to a reasonable person in the defendant’s physical circumstances an attempt by the police to capture or seize or otherwise to significantly intrude on the person’s freedom of movement.” ; accord United States v. Mendenhall , 446 U.S. 544, 554-55 (1980).
Thomas Randal Schreyer v. Commissioner of Public Safety Minn. Ct. App. 2019
State v. Hanson , 2 2 upon which Schreyer relies, is not to the contrary.
State of Minnesota v. Matthew William Vos Minn. Ct. App. 2019
The Minnesota Supreme Court addr essed this very question in State v. Hanson
State of Minnesota v. Willie Alonso Smith Minn. Ct. App. 2019
(noting that an officer’s use of flashing squad lights in many situations “would signal to a reasonable person that the officer is attempting to seize the person for investigative purposes”).
State of Minnesota v. Scott Erwin Flowers Minn. Ct. App. 2019
4 In support of its argument regarding the use of emergency ligh ts, a case where the supreme co urt held that a police officer’s use of flashing red lights when pulling up and stopping behind a car on the shoulder of a highway at night did not render the encounter a s eizure.
State of Minnesota v. Ethan Malcolm Shepherd Minn. Ct. App. 2018
(Hanson I), rev’d, (Hanson II).
State of Minnesota v. Mary Catherine Wento Minn. Ct. App. 2018
State of Minnesota v. Benji Kenneth Woehle Minn. Ct. App. 2018
This principle is clearly stated in the supreme court ’s (Hanson II).
Paul Robert Mix v. Commissioner of Public Safety Minn. Ct. App. 2017
5 he was not free to leave.” E.D.J., d at 783; see State v. Cripps , d 388, 391 (Minn. 1995) (stating that a seizure occurs when the circumstances show that a reasonable person wo uld have believed that he was neither free to disre gard the police questions nor free to end the encounter); State v. Hanson , (“[T]he question to be asked by the reviewing court is whether, looking at all of the facts, the conduct of the police would communicate to a reason able person in the defendant’s physical cir
State of Minnesota v. Travis Richard Otto Minn. Ct. App. 2016
State of Minnesota v. Travis Richard Otto Minn. Ct. App. 2016
(stating that a seizure occurs when, “looking at all of the facts, the conduct of the police would communicate to a reasonable person in the defendant’s physical circumstances an attempt by the police to capture or seize or otherwise to significantly intrude on the person’s freedom of movement”)
State of Minnesota v. Kevin Earl Westergaard Minn. Ct. App. 2016
State of Minnesota v. Kevin Earl Westergaard Minn. Ct. App. 2016
Rita Dolores Illi v. Commissioner of Public Safety 873 N.W.2d 149 Minn. Ct. App. 2015
Rita Dolores Illi v. Commissioner of Public Safety 873 N.W.2d 149 Minn. Ct. App. 2015
Unlike a squad car’s red or blue emergency lights—the use of which frequently (but not always) communicates a seizure, (“A driver confronted with a trailing squad car with flashing red lights inevitably feels duty bound to submit to this show of authority by pulling over.”), (deeming erroneous a holding “that whenever an officer turns on the squad car’s flashing red lights before getting out and approaching an already stopped car, the officer turns the encounter into a seizure”)—white spotlights
State of Minnesota v. Erik Edward Malmquist Minn. Ct. App. 2015
State of Minnesota v. Erik Edward Malmquist Minn. Ct. App. 2015
A reasonable person would have assumed that the officer was not doing anything other than checking to see what was 4 going on and to offer help if needed.” –220 (Minn. 1993).
State of Minnesota v. Christopher Steven Pettinelli Minn. Ct. App. 2014
State of Minnesota v. Christopher Steven Pettinelli Minn. Ct. App. 2014
“[A] person has been seized if in view of all of the 13 circumstances surrounding the incident, a reasonable person would have believed that he or she was neither free to disregard the police questions nor free to terminate the encounter.” (stating that the question to be asked is whether, “looking at all of the facts, the conduct of the police would communicate to a reasonable person in the defendant’s physical circumstances an attempt by the police to capture or seize or otherwise to significa
State of Minnesota v. Paul Joseph Cunningham Minn. Ct. App. 2014
State of Minnesota v. Paul Joseph Cunningham Minn. Ct. App. 2014
A reasonable person would have assumed that the officer was not doing anything other than checking to see what was going on and to offer help if needed.” -20 (Minn. 1993).
State v. Klamar 823 N.W.2d 687 Minn. Ct. App. 2012
State v. Klamar 823 N.W.2d 687 Minn. Ct. App. 2012
State v. Lopez 698 N.W.2d 18 Minn. Ct. App. 2005
State v. Lopez 698 N.W.2d 18 Minn. Ct. App. 2005
State v. Bergerson 659 N.W.2d 791 Minn. Ct. App. 2003
State v. Bergerson 659 N.W.2d 791 Minn. Ct. App. 2003
(holding that officer “boxing in [suspect’s] car, then activating his squad’s flashing red lights and honking his horn” created a seizure); -20 (Minn.1993) (concluding there was no seizure where officer, suspecting no criminal activity, activated flashing red lights upon approaching already stopped car).
Dokman v. County of Hennepin 637 N.W.2d 286 Minn. Ct. App. 2001
Dokman v. County of Hennepin 637 N.W.2d 286 Minn. Ct. App. 2001
220 & n. 1 (Minn.1993) (citing United States v. Mendenhall, 446 U.S. 544, 554-55 , 100 S.Ct.
State v. Riley 568 N.W.2d 518 Minn. 1997
State v. Riley 568 N.W.2d 518 Minn. 1997
220 & n. 1 (Minn.1993) (citing United States v. Mendenhall, 446 U.S. 544, 554-55 , 100 S.Ct.