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DWI Case Of The Week is Peach v. Commissioner of Public Safety (Decided September 23, 2024, Minnesota Court of Appeals, Unpublished) which stands for the proposition that if you are not valid to obtain a driver's license in the State where the DWI was committed, you are not valid to obtain a driver's license in Minnesota.

Mr. Peach had three prior DWI's from Minnesota when he committed a fourth DWI in Wisconsin in 2021.  The Wisconsin conviction resulted in a "lifetime revocation" of his Wisconsin privilege to drive a motor vehicle.

In 2023, Mr. Peach applied for a Minnesota driver's license and sought to enroll in the Interlock program which would allow him to have an interlock-limited license. The application was denied because his driving privilege was still revoked in Wisconsin.

Mr. Peach filed a challenge in district court to the denial of his Minnesota license request but the district court sustained the application denial.  On appeal, the Court of Appeals affirmed the district court noting:

"Because appellant had three prior DWI offenses, under Wisconsin law he received a “lifetime” revocation of his driving privileges, and because appellant’s driving privileges have been revoked in Wisconsin, he may not apply for a driver’s license in Minnesota. See Minn. R. 7410.5500, subp 2 (“If an applicant’s driving privileges are withdrawn in any other state and the applicant applies for a driver’s license in Minnesota, then the applicant’s driving privileges must be reinstated in all other states before the applicant is eligible for driving privileges in Minnesota . . . .”)."

"Appellant argues that this is an “absurd” result because, if he had committed his fourth offense in Minnesota instead of in Wisconsin, he could enroll in IID. That may be true; persons who are convicted of a fourth Minnesota DWI offense are not necessarily convicted of violating Minn Stat. § 171.17, subd. 1(a)(9), and, if the statute they did violate is among those specified in Minn. Stat. § 171.306, subd. 4(c), (d) (listing those eligible for the IID program), they are eligible to enroll."

"But it is also true that courts may presume the legislature does not intend an absurd result. Minn. Stat. § 645.17(1) (2022). The legislature’s determination that persons with outstanding license revocations in other states should not be allowed to obtain a Minnesota license through the IID program is not absurd. “[C]onvictions of another state should generally be recognized in the forum state . . . [unless] strong public policy interests of the forum state provide sufficient reason to override the general rule of recognition.” State v. Schmidt, 712 N.W.2d 530, 537, 539 (Minn. 2006)".

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"It is equally true that this court “cannot supply that which the legislature purposely omits or inadvertently overlooks.” Martinco v. Hastings, 122 N.W.2d 631, 638 (Minn. 1963). Thus, whether appellant would be entitled to enroll in IID if his fourth offense had been committed in Minnesota is irrelevant; his offense was committed in Wisconsin, is not included in Minn. Stat. § 171.306, subd. 4(c), (d), and this court cannot sua sponte include it."

Moral Of The Story:  If you are going to drink, stay home.

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.