The Minnesota DWI Case Of The Week is State v. Carstensen (Decided November 4, 2019, Minnesota Court of Appeals, Unpublished) which stands for the proposition that everyone is presumed to know the law unless you happen to be a police officer plying your trade on the streets of Minnesota.
In Carstensen, the Defendant was driving a vehicle with Iowa plates on July 2, 2018. The expiration date on the Iowa plates was June 2018. A Beltrami County sheriff's deputy observed the vehicle and made a traffic stop, eventually arresting Mr. Carstensen for DWI.
The Defendant filed a motion to suppress arguing the initial stop was illegal because Iowa’s registration-expiration statute provides, “[a] person shall not be considered to be driving a motor vehicle with an expired registration for a period of one month following the expiration date of the vehicle registration.” And the Minnesota reciprocity statute provides that "a vehicle properly registered in Iowa will be treated as properly registered in Minnesota even if the Iowa requirements are different. See Minn. Stat. § 645.26, subd. 1 (2018)". The Defendant's motion to suppress was denied.
In State v. George, the Minnesota Supreme Court held "...that an officer’s mistaken belief as to Minnesota law cannot support an objective basis for an investigatory stop." So one would think that the Court of Appeals would have reversed the district court. But no...
The Minnesota Court of Appeals instead affirmed the conviction, stating:
"We conclude that this case is distinguishable from George and Anderson. In George and Anderson, the circumstances that the officers observed could not have constituted violations of Minnesota law and were premised on the officers’ mistaken belief as to the meaning of a Minnesota statute. Here, Deputy Birt’s discovery of the registration with a June 2018 expiration could have been a violation of the general Minnesota statute. Only by way of the reciprocity statute was Carstensen’s registration valid. While the record is admittedly sparse, nothing indicates that Deputy Birt was mistaken as to the meaning of a Minnesota statute in this case."..."Because Deputy Birt was unaware that the Iowa vehicle registration was not expired for one month beyond the Minnesota requirements, it was not unreasonable for him to stop Carstensen’s vehicle for violating Minnesota Law".
Moral Of The Story: Ignorance is bliss!
In State v. George, the Minnesota Supreme Court held "...that an officer’s mistaken belief as to Minnesota law cannot support an objective basis for an investigatory stop." So one would think that the Court of Appeals would have reversed the district court. But no...
The Minnesota Court of Appeals instead affirmed the conviction, stating:
"We conclude that this case is distinguishable from George and Anderson. In George and Anderson, the circumstances that the officers observed could not have constituted violations of Minnesota law and were premised on the officers’ mistaken belief as to the meaning of a Minnesota statute. Here, Deputy Birt’s discovery of the registration with a June 2018 expiration could have been a violation of the general Minnesota statute. Only by way of the reciprocity statute was Carstensen’s registration valid. While the record is admittedly sparse, nothing indicates that Deputy Birt was mistaken as to the meaning of a Minnesota statute in this case."..."Because Deputy Birt was unaware that the Iowa vehicle registration was not expired for one month beyond the Minnesota requirements, it was not unreasonable for him to stop Carstensen’s vehicle for violating Minnesota Law".
Moral Of The Story: Ignorance is bliss!
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.
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