Felony drug charge dismissed

Case

State v. Tate
62-CR-23-3731
Ramsey County District Court
2nd Judicial District

The motion to suppress was granted and the charge was dismissed. Case closed.

A traffic stop for an alleged turn signal violation led to a felony fifth-degree controlled substance charge after an officer pulled over the client and ultimately recovered suspected fentanyl.

The entire case rested on what the officer claimed to have seen at one intersection on one evening.

The legal approach

Thomas moved to suppress everything — and the court’s own review of the squad camera footage showed the stop should never have happened.

The motion challenged the stop on three independent grounds.

First, the alleged traffic violations did not occur.

The officer claimed the client had improperly stopped in an intersection and then failed to signal while pulling over. Thomas submitted the squad dashboard and body camera footage that directly contradicted both claims. The footage showed that as the client began to enter the intersection, a white van — partially obscured by large rocks and trees on the passenger side — was crossing perpendicular to him. The client briefly paused to let the van pass safely, then proceeded. That was not a traffic violation. As for the failure to signal, the client pulled over immediately after the officer executed an aggressive U-turn and came up behind him on an otherwise empty road. Thomas argued — and the court agreed — that promptly pulling over in response to a police vehicle coming up behind you is a “good and sufficient reason” for not signaling, as recognized under Minnesota law. The officer was wrong on both counts.

Second, even if the stop had been valid, it was unlawfully expanded from the moment the officer opened his mouth.

The body camera captured the officer’s very first question to the client after approaching the vehicle: “Any marijuana or drugs on you?” — at timestamp 1:26, before any traffic violation had been investigated, before any license check, before any basis specific to the client had been established. Thomas cited State v. Fort and State v. Syhavong to establish that asking about drugs at a traffic stop — without reasonable suspicion particularized to the driver — is an unlawful expansion of the stop regardless of how quickly it happens. Later in the stop, the officer told an arriving colleague that he planned to search the vehicle because the client had “said something about little marijuana leaves or whatever.” Thomas put that statement before the court as the officer’s own admission that the drug investigation had been the goal from the outset — not a consequence of lawfully developing facts.

Third, the motion argued that even a technically valid traffic stop can be unconstitutional when it is used as a pretext to investigate someone for reasons unrelated to traffic enforcement.

Thomas cited State v. George and State v. Askerooth for the proposition that the Minnesota Constitution provides greater protection against pretextual stops than federal law does — and that the officer’s immediate pivot to drug questioning, without any individualized basis, revealed that this stop was not about traffic enforcement at all.

The result

The District Court agreed.

After reviewing the squad camera footage, the court found that neither alleged traffic violation had actually occurred. The client’s brief pause in the intersection was a reasonable response to an oncoming vehicle, not an illegal stop. His failure to signal before pulling over was a reasonable response to a police car executing a rapid U-turn directly behind him on an empty road — which the court found constituted the “good and sufficient reason” the statute requires. Because no valid traffic violation had occurred, the officer had no lawful basis to stop the vehicle. Everything recovered as a result of that stop — including the controlled substance — was suppressed as the fruit of an illegal seizure.

The charge was dismissed.

Disclaimer
This case has been anonymized to protect client confidentiality. Past results do not guarantee or predict future outcomes. Every case is different, and the result in any particular matter depends on its specific facts, the applicable law, and the circumstances of each client.