State v. Leonard
Minnesota Supreme Court
943 N.W.2d 149 (2020)

- Written by Sean Carroll, JD
Facts
Law enforcement showed up at a hotel and asked to the see guest registry. The officers did not have a warrant or any specific suspicion of a crime but were conducting an interdiction, meaning an attempt by law enforcement to intercept drugs or other illegal contraband before they reach their intended destination. The officers singled out John Leonard (defendant) because hotel staff stated that he had paid for his room in cash. The officers conducted a background check and, through that, developed an individual suspicion about Leonard. The officers went to Leonard’s room without a warrant and captured Leonard when he attempted to run away. The officers then obtained a warrant to search his room and found suspicious checks, which they thought might be forged. Leonard was charged with forgery. Leonard filed a motion to suppress the evidence found at the hotel room on the ground that it was obtained after an illegal search. The motion was denied. Leonard appealed.
Rule of Law
Issue
Holding and Reasoning (Hudson, J.)
Dissent (Gildea, C.J.)
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