The Minnesota DWI Case Of The week is State v. Peterson (Decided February 27, 2023, Minnesota Court of Appeals, Unpublished), which stands for the proposition that a stop of a motor vehicle is valid if the stop is based upon a reasonable mistake of fact.
In Peterson, the Defendant was stopped because the police officer ran a license plate inquiry on the Defendant's vehicle and the inquiry revealed the Defendant's license was cancelled. The Defendant was eventually arrested for Felony DWI and a search of his vehicle revealed drug paraphernalia and methamphetamine.
Peterson moved the suppress the evidence arguing the stop was unconstitutional. The deputy testified that the DVS system indicated that Peterson’s driving status was canceled-IPS. That testimony was supported by the district court’s receipt of a certified copy of Peterson’s driving record, which indicated that his license was canceled-IPS when the stop occurred. The district court concluded that the information from the DVS provided a lawful basis for the traffic stop and denied the motion to suppress.
Peterson appealed arguing that his convictions must be reversed because the state failed to prove that his driving privileges were “actually canceled” at the time of the traffic stop.
The Minnesota Court of Appeals affirmed the conviction, noting:
"When an officer observes a violation of the traffic laws, there is reasonable suspicion to stop the vehicle.” State v. Poehler, 935 N.W.2d 729, 733 (Minn. 2019). But the “actual violation of the vehicle and traffic laws need not be detectable.” State v. Pike, 551 N.W.2d 919, 921-22 (Minn. 1996). The police need only “show that the stop was not the product of mere whim, caprice or idle curiosity, but was based upon specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion.”
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"Traffic stops are routinely based on DVS record checks conducted from police squad cars. See, e.g.. Pike, 551 N.W.2d at 921-22 (upholding traffic stop based on officer’s license-plate check, which revealed the registered owner’s license was revoked). And the Minnesota Supreme Court has held that “[i]t is constitutional for an officer to make a brief, investigatory, [traffic] stop of a vehicle if the officer knows that the owner of the vehicle has a revoked license,” as long as the officer is “unaware of any facts which would render unreasonable an assumption that the owner is driving the vehicle.” Id. at 920. Under the reasoning of Pike, we similarly conclude that it is constitutional for an officer to make a traffic stop based on current DVS records, so long as the officer is unaware of any facts that would make an assumption that the records are accurate unreasonable. The record does not reveal any basis to conclude that the deputy in this case was aware of such facts."
"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 of fact are unobjectionable under the Fourth Amendment.” State v. Licari, 659 N.W.2d 243, 254 (Minn. 2003). So long as the deputy was unaware of any facts reasonably suggesting that the DVS records regarding Peterson’s license status were inaccurate, his reliance on incorrect DVS records would constitute an unobjectionable mistake of fact...absent a showing that the officer’s reliance on the accuracy of the DVS records was unreasonable, the records provided a lawful basis for the traffic stop, regardless of their accuracy."
Moral Of The Story: Close enough for government work!
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.
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