Tuesday, September 3, 2019

Minnesota DWI Lawyer F. T. Sessoms Blogs on Minnesota DWI: This Week's Featured Minnesota DWI Case

The Minnesota DWI Case Of The Week is Jensen v. Commissioner of Public Safety (Decided September 3, 2019, Minnesota Court of Appeals, Published) which stands for the proposition that the advisory must be read before the Commissioner can conduct a pre-hearing license revocation pursuant to Minnesota Statute §171.177.

In Jensen, the arresting police officer obtained a search warrant to draw and test Pauline Jensen’s blood after she drove into and injured a child with her car and failed field sobriety tests. The blood test showed that Jensen’s alcohol concentration exceeded the statutory limit, and the commissioner of public safety revoked her license under Minnesota Statutes, section 171.177, subdivision 5.

Jensen petitioned for judicial review, arguing that her driver’s license should be reinstated because the sergeant had not warned her that test refusal is a crime, as required by Minnesota Statutes, section 171.177, subdivision 1 (2018).  The District Court sustained the license revocation but on Appeals, the Minnesota Court of Appeals reversed the lower court stating:

"The statute requires that, “[a]t the time a blood or urine test is directed pursuant to a search warrant. . . , the person must be informed that refusal to submit to a blood or urine test is a crime.” Minn. Stat. § 171.177, subd. 1. We recently concluded that the warning requirement is unambiguous, has no exceptions, and requires an officer to inform an individual of the criminal consequences of test refusal even when a warrant authorizes the blood draw. State v. Mike, 919 N.W.2d 103, 110 (Minn. App. 2018), review granted (Minn. Nov. 13, 2018)."
***
"The procedures in section 171.177 largely mirror those stated in the implied-consent statutes, requiring a warning of criminal consequences at the time a test is directed or requested. Compare Minn. Stat. § 171.177, subd. 1, with Minn. Stat. § 169A.51, subd. 2 (2018). The statutes also detail the same procedure for review of a revocation. Compare Minn. Stat. § 171.177, subds. 10-12 (2012), with Minn. Stat. § 169A.53 (2018). The history of section 171.177 and its obvious relationship to the implied-consent statutes leads us to apply to section 171.177 the caselaw relied on to interpret the related implied-consent statutes."

"The supreme court’s decision in Tyler v. Commissioner of Public Safety is most instructive. 368 N.W.2d 275, 280-81 (Minn. 1985). Tyler compels us to hold that the deputy’s failure to provide the statutorily required warning precluded the district court from upholding Jensen’s revocation. Id. The Tyler court held that complying with the warning requirement was necessary before revoking a license under the implied-consent law: “[W]e believe that the legislature intended that a driver’s license be revoked pursuant to the implied consent law . . . only if the provisions of the law were complied with.” Id. at281 (emphasis added). And a license revocation cannot be sustained if the refusal-is-a-crime warning was not given. Id. Following this reasoning, we hold that a license can be revoked under section 171.177 only if the officer followed the warning requirement."
***
"It is true that, if Jensen had refused to submit to the test, the sergeant could have drawn and tested her blood anyway. But an officer’s authority to obtain a test despite the driver’s refusal does not eliminate his duty to give the warning “at the time a blood or urine test is directed.” Minn. Stat. § 171.177, subd. 1. Nor does the authority render the warning irrelevant. As we have explained, the purpose of the warning is “to inform a driver of the serious consequences of refusal in an effort to compel the driver to take the test,” not to inform the driver that she has the option to refuse. Mike, 919 N.W.2d at 113. And a driver can commit the crime of test refusal even if she is ultimately forced to submit to a test. See Minn. Stat. §§ 169A.20, subd. 2(2), 171.177, subd. 13(a)-(b) (2018). Because refusing a test carries the same criminal consequences whether or not the state can force a test, and because the purpose of the warning is to inform drivers of the criminal consequences of refusal, the warning serves its purpose and is not irrelevant in these circumstances. The refusal-is-a-crime warning is required before the commissioner may secure a pre-hearing license revocation."

Moral Of The Story:  Police must warn you before your license can be revoked!

If you or a loved one have been arrested for a Minnesota DWI, or are facing a DWI forfeiture of your motor vehicle, feel free to contact Minnesota DWI Lawyer, F. T. Sessoms at (612) 344-1505 for answers to all of your Minnesota DWI questions.



Tuesday, August 27, 2019

Minnesota DWI Attorney F. T. Sessoms Blogs on Minnesota DWI: This Week's Featured Minnesota DWI Case

The Minnesota DWI Case Of The Week is State v. Howell (Decided August 26, 2019, Minnesota Court of Appeals, Unpublished), which stands for the proposition that there is no right to counsel, even for a DWI refusal, when the test is requested pursuant to a search warrant.  I can't blame the Court of Appeals for this decision as they are just following the recent Minnesota Supreme Court decision of State v. Rosenbush.  The problem is Rosenbush ( a 4 to 3 decision) makes no sense.

In Howell, the Defendant was arrested for DWI and while at the jail, the officer obtained a search warrant for Howell’s blood. The officer advised Howell that refusal to submit to blood-alcohol testing is a crime and asked Howell if he would submit to a blood or urine test. See Minn. Stat. § 171.177, subd. 1 (Supp. 2017) (“At the time a blood or urine test is directed pursuant to a search warrant under sections 626.04 to 626.18, the person must be informed that refusal to submit to a blood or urine test is a crime.”). Howell asked for a lawyer, but was not allowed to contact one. Howell refused to provide a sample for testing.

Howell contended that the police violated his limited right to counsel under the Minnesota Constitution because he requested counsel before the police asked him to submit to chemical testing and the police did not accommodate that request.  

The Minnesota Court of Appeals rejected Howell's argument stating:

"After oral argument in this case, the supreme court decided State v. Rosenbush, which squarely addresses the issue presented in this case: whether a driver arrested on suspicion of DWI and presented with a search warrant authorizing a search of his blood has a limited right to counsel under article I, section 6 of the Minnesota Constitution, as recognized in Friedman, before deciding whether to submit to chemical testing."
***
"The supreme court agreed with the state and held that the limited right to counsel established in Friedman does not apply when an individual is asked to submit to a blood test pursuant to a warrant. Id. at * 1, *5-6. The supreme court reasoned that “the existence of a search warrant eliminates many of the concerns that led [it] to expand the right to counsel in Friedman,” explaining that when a suspected impaired driver is presented with a search warrant for a blood or urine test, “the driver is not meeting his adversary in the same manner as the driver in Friedman because a neutral judicial officer has determined that the police may lawfully obtain a sample of the driver’s blood."

What the Supreme Court in Rosenbush totally fails to address is the rationale for Friedman, to wit:  When a person has been placed under arrest for DWI and been asked to submit to testing, the arrestee is facing IMMEDIATE CONSEQUENCES for their testing decision.  If they refuse, they immediately lose their license for one year and are facing prosecution for the gross misdemeanor crime of refusal.  It was these "immediate consequences" of the testing decision that led the Supreme Court in Friedman to hold that a person has the right to consult with counsel prior to testing.  The fact that a "neutral and detached" magistrate has reviewed the warrant application has nothing to do with the testing dilemma facing the person under arrest for DWI.  

Rosenbush is a stupid decision. Period.

Moral Of The Story: You can be the supreme court and still not get it right.

If you or a loved one have been arrested for a Minnesota DWI, or are facing a DWI forfeiture of your motor vehicle, feel free to contact Minnesota DWI Attorney, F. T. Sessoms at (612) 344-1505 for answers to all of your Minnesota DWI questions.


Wednesday, August 14, 2019

Minneapolis DWI Attorney F. T. Sessoms Blogs on Minnesota DWI: This Week's Featured Minnesota DWI Case

The Minnesota DWI Case Of The Week is State v. Kalkbrenner (Decided August 12, 2019, Minnesota Court of Appeals, Unpublished) which stands for the proposition that the police can make stuff up to justify an automobile stop and as long as the court calls their claim a "reasonable mistake of fact" the stop will be upheld.

In Kalkbrenner, a police officer observed that the taillights on appellant’s vehicle were not illuminated and initiated a traffic stop. While speaking with appellant, the officer noticed multiple indicia of intoxication and placed appellant under arrest. Appellant was charged with third-degree impaired driving and a taillight infraction. Appellant moved to suppress the evidence obtained as a result of the stop, arguing that the officer mistakenly thought the vehicle’s taillights were not illuminated and his mistake was objectively unreasonable. The parties stipulated to the underlying facts of the case and submitted the police reports and a statement from an automotive expert, which stated it is impossible to turn on the headlights without also turning on the taillights and that an examination of the vehicle four days after the stop indicated that all the lights were in working order. The district court did not hear any testimony and decided the matter based on the stipulated facts and briefing by the parties. The court assumed that the officer’s “observation of the taillights on [appellant]’s vehicle [w]as a mistake of fact,” and denied the motion to suppress on the ground that the officer’s mistake was reasonable.

On appeal the Minnesota Court of Appeals upheld the district court, stating:

"Given the unrebutted expert testimony and the report from the body shop, the district court found that the officer “may have made a mistake of fact” regarding the taillights. However, the court concluded that “[b]ased upon the stipulated record before the Court, assuming [the officer]’s observation of the taillights on [the] vehicle as a mistake of fact, the Officer’s mistake was reasonable.”2 Minnesota law recognizes that an officer’s “honest, reasonable mistakes of fact are unobjectionable under the Fourth Amendment.” State v. Licari, 659 N.W.2d 243, 254 (Minn. 2003). Further, a good-faith and reasonable mistake of fact will not invalidate an otherwise valid stop. See State v. Sanders, 339 N.W.2d 557, 560 (Minn. 1983) (holding that stop based on a reasonable mistake of identify was lawful). Even if the officer made a mistake of fact as to the taillights, there is no evidence in this record that his mistake was the product of “mere whim, caprice, or idle curiosity” or unreasonable. State v. Pike, 551 N.W.2d 919, 921-22 (Minn. 1996). As such, the officer’s traffic stop was not “unobjectionable under the Fourth Amendment.” Licari, 659 N.W.2d at 254."

I can't object to the appellate court's analysis as they were stuck with the district court's finding that the mistake was "reasonable". But the district court's ruling that the mistake was "reasonable" is absurd.  Either the tail lights were on or they were off.  Their condition is not something that is "reasonably mistaken". I know that when I drive down the highway, I often cannot tell if the car in front of me has working tail lights at night.  I mean, give me a break.

Moral Of The Story:  Get the squad video for every DWI case.



If you or a loved one have been charged with a Minnesota DWI, feel free to contact Minneapolis DWI Attorney, F. T. Sessoms at (612) 344-1505 for answers to all of your Minnesota DWI and DUI questions.





Monday, August 5, 2019

Minneapolis DWI Lawyer F. T. Sessoms Blogs on Minnesota DWI: This Week's Featured Minnesota DWI Case

The Minnesota DWI Case of the Week is State v. Preston (Decided August 5, 2019, Minnesota Court of Appeals, Unpublished) which stands for the proposition that the police may conduct a traffic stop if they observe a partially obscured license plate.

In Preston, Beltrami County Sheriff's Deputy Bender was monitoring traffic when the Defendant drove past.  The Deputy was unable to read Defendant's license plate number as it was obstructed by a dangling light.

Deputy Bender initiated a traffic stop. He then approached the car and recognized the Defendant. Deputy Bender knew Defendant's driver’s license was cancelled. Preston was arrested and Deputy Bender searched the vehicle and found numerous smoking devices, marijuana, and an open container of alcoholic iced tea. Appellant admitted to smoking methamphetamine six hours earlier. A search warrant was obtained and executed, and appellant’s blood tested positive for methamphetamine.

Defendant was charged with driving after cancellation, DWI and 5th Degree possession. Mr. Preston filed a motion to suppress arguing the initial stop of his vehicle was not valid. 

The District Court denied the motion to suppress and on appeal, the Minnesota Court of Appeals affirmed, stating:

"Minnesota law prohibits obstructing the view of a license plate. “The person driving the motor vehicle shall keep the plate legible and unobstructed ... so that the lettering is plainly visible at all times.” Minn. Stat. § 169.79, subd. 7 (2016). In finding that appellant violated this traffic law, the district court relied on a photograph of the license plate and testimony from Deputy Bender. The photograph, taken at the time of the traffic stop, shows a light dangling over the last three letters of the license plate. One letter is obstructed and another letter is partially obstructed. Further, Deputy Bender testified that the light made the license plate “difficult to see.” Because the record supports the district court’s factual finding that the license plate was obstructed and this provided Deputy Bender with a reasonable, articulable suspicion to stop appellant’s vehicle, we affirm."

Moral Of The Story: He should have joined the "clean plate" club!



If you or a loved one have been charged with a Minnesota DWI, feel free to contact Minneapolis DWI Lawyer, F. T. Sessoms at (612) 344-1505 for answers to all of your Minnesota DWI and DUI questions.


Monday, July 1, 2019

Minnesota DWI Lawyer F. T. Sessoms Blogs on Minnesota DWI: This Week's Featured Minnesota DWI Case

The Minnesota DWI Case Of The Week is State v. Cunningham (Decided July 1, 2019, Minnesota Court of Appeals, Unpublished) which stands, once again, for the well established rule that if a police officer observes a traffic violation, the officer has a sufficient basis to make the stop of the vehicle. Yawn.

In Cunningham, Minneapolis Police Officer Andrew Braun and his partner were on patrol driving eastbound on Plymouth Avenue North. The officers had a green light as they approached the intersection of Plymouth and Washington Avenue North. When the officers were approximately 75 to 100 yards away from the intersection, they saw five or six vehicles speed through the intersection travelling southbound on Washington. Because the light was green for traffic going east on Plymouth, Officer Braun knew that traffic going north and south on Washington had a red light.

The officers conducted a traffic stop on a white truck, driven by appellant, which was a part of the convoy of vehicles that had gone through the red light on Washington.  Based upon events after the stop of Cunningham’s truck, Mr. Cunningham was charged with one count of operating a motor vehicle while under the influence of alcohol in violation of Minn. Stat. § 169A.20, subd. 1(1) (2016).

The Defendant was convicted after a trial on stipulated facts and on appeal,Cunningham argues that there was no reasonable, articulable suspicion to support Officer Braun’s stop of his truck, and that the district court erred by denying his motion to suppress the evidence obtained from the stop.

The Minnesota Court of Appeals affirmed the district court, noting:

"...a police officer may initiate a limited, investigative stop without a warrant if the officer has reasonable, articulable suspicion of criminal activity. State v. Munson, 594 N.W.2d 128, 136 (Minn. 1999) (citing Terry v. Ohio, 392 U.S. 1, 88 S. Ct. 1868 (1968)). The reasonable-suspicion standard is not a high one, State v. Diede, 795 N.W.2d 836, 843 (Minn. 2011), but the investigatory stop may not be the result of “mere whim, caprice or idle curiosity,” State v. Pike, 551 N.W.2d 919, 921-22 (Minn. 1996). If an officer observes a violation of a traffic law, even one that is insignificant, there is an objective basis for an investigatory stop. State v. George, 557 N.W.2d 575, 578 (Minn. 1997).

Cunningham also argued that the officer's testimony should not have been believed by the district court after Cunningham testified that he did not run a red light.  

The appellate court, however, rejected his argument, pointing out:

"This court gives deference to the fact-finder—especially where resolution of the case depends on conflicting testimony—because weighing the credibility of witnesses is its exclusive function.  State v. Pieschke, 295 N.W.2d 580, 584 (Minn. 1980)."

Moral Of The Story: Some appeals are just stupid. 

If you or a loved one have been arrested for a Minnesota DWI, or are facing a DWI forfeiture of your motor vehicle, feel free to contact Minnesota DWI Lawyer, F. T. Sessoms at (612) 344-1505 for answers to all of your Minnesota DWI questions.


Monday, June 24, 2019

Minnesota DWI Attorney F. T. Sessoms Blogs on Minnesota DWI: This Week's Featured Minnesota DWI Case

The Minnesota DWI Case Of The Week is State v. Handeland (Decided June 24, 2019, Minnesota Court of Appeals, Unpublished) which stands for the proposition that ANY time spent in a Minnesota jail or for a mental evaluation must be credited when imposing jail time for an unrelated offense.

In 2012, the Defendant was convicted of First Degree DWI in Mille Lacs County and was given a sentence of 42 months stayed, with the Defendant to serve to 180 days jail, 60 of which were done in the jail facility with the remainder on electronic home monitoring. 

Mr. Handeland was arrested in April 2016 in Benton County for Felony DWI.  The District Court in Benton County found the Defendant incompetent to stand trial and he was ordered into the state's competency restoration program at the  Anoka County Treatment Center. Mr. Handeland was found competent in November 2016 and his Benton County case resumed, resulting in a guilty plea in April 2018.

In between the Defendant's return to competency and his April 2018 plea, he managed to get arrested on two separate fifth-degree controlled-substance offenses and spent additional days in local jails related to those offenses.

At the Defendant's 2018 sentencing in Benton County, the district court sentenced Handeland to 60 months in prison, stayed execution of the sentence and placed him on probation for seven years. The court awarded the Defendant 194 days of jail credit.

Mille Lacs County then brought the Defendant back to face a probation revocation hearing. The district revoked Handeland's probation and sentenced him to 42 months in prison and only awarded the Defendant eight days of custody credit.  How stupid!

On appeal, the Minnesota Court of Appeals reversed the lack of custody credit and does a nice job explaining when a Defendant is entitled to credit for jail time and treatment. As stated by the Court:

"Between his 2012 Mille Lacs County arrest for DWI and the 2018 execution of his 42-month sentence for that DWI, Handeland spent approximately 389 days in custody. Those days largely fall into three buckets: the days spent in the Mille Lacs County jail related to the 2012 DWI; the days spent in local jails related to other convictions (primarily an additional DWI arrest and conviction in Benton County) and days spent in examination and treatment as part of his competency restoration. To properly calculate Handeland’s custody credit, we first address the Mille Lacs County jail time, clearly related to the underlying DWI conviction. Next, because both the second and third buckets of days involve unconnected cases, we then turn to the issue of how to evaluate credit for intrajurisdictional custody. Finally, we address the custody-credit standards for secure treatment for competency-restoration purposes."

60 Days In Mille Lacs County Jail:

"The Minnesota Rules of Criminal Procedure clearly state that a criminal defendant is entitled to jail credit for time spent in custody “in connection with the offense or behavioral incident being sentenced.” Minn. R. Crim. P. 27.03, subd. 4(B) (emphasis added). As the state concedes on appeal, although these days were not discussed at Handeland’s probation-violation hearing, they clearly were time spent in custody in connection with the original sentence and should count as custody credit."

Credit for Custody in Unconnected Cases:

In State v. Brown, the Minnesota Supreme Court held that jail time spent out-of-state will not be credited unless it is connected to the offense for which the Defendant is being sentenced.  But this does not apply to in-state, but unrelated cases.  The reason is, "In evaluating credit for intrajurisdictional custody, we seek to avoid four potential concerns: “de facto conversion of a concurrent sentence into a consecutive sentence; indigent persons serving effectively longer sentences as a result of their inability to post bail; irrelevant factors . . . affecting the length of incarceration; and manipulation of charging dates by the prosecutor so as to increase the length of incarceration"(citations omitted).

"Having reviewed the governing approach to intrajurisdictional credit, we turn to the time Handeland spent in other local jails. This constitutes 194 days—primarily related to the Benton County DWI—between his original Mille Lacs County sentencing and his probation revocation five years later....To deny credit without evaluating these days in light of the intrajurisdictional approach described above was error."

Mental Health Treatment Credit:

The Court of Appeals notes that Rule 20.01, subd. 11, states: "If the defendant is convicted, any time spent confined to a hospital or other facility for a mental examination under this rule must be credited as time served."

"As the state suggests, the rule only dictates jail credit for the examination period. Minn. R. Crim. P. 20.01, subd. 11. But our inquiry does not end with this rule. As this court explained in Bonafide, the language of the rule may simply not address—rather than affirmatively exclude—credit for competency-restoration treatment during a commitment."

"And to examine this issue of credit for treatment, the Bonafide court first looked at the supreme court’s expansion of custodial credit, in light of “the philosophy behind the rule.” Id. at 214. This court also, citing other state court decisions, explained that “the degree of deprivation of liberty in a mental commitment facility is equivalent to a jail or prison facility.” Id. And this court took note of the ABA Criminal Justice Mental Health Standard, which provides that a defendant detained for examination of competence “or treatment... to effect competence to stand trial should receive credit against any sentence ultimately imposed for the time of such pretrial confinement.” Id. at 215. As a result, the Bonafide court interpreted rules 20.01 and 27.03, subd. 4, as requiring credit against sentence for custodial time spent in a secure hospital under a rule 20 presentence commitment procedure.  We see no reason to retreat from Bonafide, to the more restrictive reading of rule 20 the state suggests."

Moral Of The Story:  In Minnesota, we give credit where credit is due!

If you or a loved one have been arrested for a Minnesota DWI, or are facing a DWI forfeiture of your motor vehicle, feel free to contact Minnesota DWI Attorney, F. T. Sessoms at (612) 344-1505 for answers to all of your Minnesota DWI questions.









Wednesday, June 19, 2019

Minneapolis DWI Attorney F. T. Sessoms Blogs on Minnesota DWI: This Week's Featured Minnesota DWI Case

The Minnesota DWI Case Of The Week is State v. Anderson (Decided June 17, 2019, Minnesota Court of Appeals, Published) which stands for the proposition that the use of a prior implied consent license revocation to enhance the severity of the current DWI charge does not violate due process provided the prior implied consent license revocation is "final" prior to the conviction for the current offense.  This case just basically follows State v. Wiltgen, 737 N.W.2d 561 (Minn. 2007).

In Anderson, the defendant was arrested for DWI on October 2, 2016 and on December 18, 2016.  Anderson filed a challenge to the October DWI license revocation but in April 2017, Anderson waived his right to further judicial review of the October license revocation.

On August 7, 2017. the state charged Anderson with 2nd Degree DWI Refusal using the October license revocation to enhance the charges stemming from his December 2016 arrest.

The Defendant filed a Motion To Dismiss the 2nd degree charge arguing that at the time the December offense was committed, the challenge to the October license revocation was not "final" and the revocation could not be used to enhance the present charge.  The Court of Appeals rejected the argument stating"

"The United States and Minnesota Constitutions guarantee due process of law for criminal defendants. U.S. Const, amend. XIV, § 1; Minn. Const, art. I, § 7. Due process requires an “opportunity to be heard at a meaningful time and in a meaningful manner.” State v. Krause, 817 N.W.2d 136, 145 (Minn. 2012) (quoting Mathews v. Eldridge, 424 U.S. 319, 333, 96 S. Ct. 893, 902 (1976)) (other quotation omitted). The United States Supreme Court has held that when an administrative proceeding, such as a license revocation, plays a “critical role” in imposing a subsequent criminal sanction, “there must be some meaningful review of the administrative proceeding.” United States v. Mendoza-Lopez, 481 U.S. 828, 837-38, 107 S. Ct. 2148, 2155 (1987). Accordingly, some “means of obtaining judicial review must be made available before the administrative order may be used to establish conclusively an element of a criminal offense."
***
"In Wiltgen, the supreme court applied the three-part test established in Mathews v. Eldridge. Id. at 568-70 (citing Mathews, 424 U.S. at 335, 96 S. Ct. at 903). After weighing the Mathews factors, the supreme court determined that the combined private interest and risk of an erroneous deprivation outweighed the government interest. Id. The supreme court held that the potential prejudice to the defendant “from the use of an unreviewed administrative revocation to enhance a subsequent DWI rises to the level of a violation of [the defendant’s] right to procedural due process.” Id. at 570."

"In footnote seven of Wiltgen, the supreme court considered whether the state was prejudiced by its ruling and determined that it was not. Id. at 572 n.7. The supreme court reasoned that, in future cases, the state “can delay the issuance of a second-degree DWI complaint until after the implied consent hearing has been conducted and the revocation has been sustained, or can charge third-degree DWI before the implied consent hearing and amend the complaint to add a second-degree DWI charge after the hearing."
***
"Like the defendant in Heino, Anderson filed, then waived review of, his petition for judicial review of his 2016 license revocation before the state served a complaint that asserted an aggravating factor for his 2016 DWI. Although Heino involved a defendant’s property interest, and Anderson’s due-process claim involves his liberty interest, the risk of an erroneous deprivation is slight for Anderson. See Heino, 762 N.W.2d at 264 (concluding that “the risk of erroneous deprivation in this case was minimal”). If Anderson had proceeded with judicial review of the 2016 license revocation and successfully obtained a rescission, then the state could not have used his revocation as an aggravating factor for his 2016 DWI."

Moral Of The Story:  If you can delay and delay and delay justice, you may be able to deny it!



If you or a loved one have been charged with a Minnesota DWI, feel free to contact Minneapolis DWI Attorney, F. T. Sessoms at (612) 344-1505 for answers to all of your Minnesota DWI and DUI questions.