default.html.twig template not found for page: /resources/legal-not-so-eze/december-2025-or-legal-case-updates-or-corpus-delicti-and-4th-amendmentAppellant proceeded to trial on a charge of misdemeanor domestic assault and the State introduced evidence that, after being called to the scene of a reported verbal domestic dispute, Appellant twice admitted to police he slapped the victim. The State also admitted a 9-1-1 call, during which the reporting party described witnessing a verbal argument and Appellant moving and making “big arm movements” towards the victim. The investigating officer also testified as to his observations and other statements made by Appellant. The district court denied Appellant’s motion for judgment of acquittal and a request that the jury be instructed, pursuant to Minn. Stat.§ 634.03, that a defendant’s confession is not sufficient to warrant a conviction without evidence that the offense has been committed. The jury found Appellant guilty.
Section 634.03, Minnesota’s corpus delicti statute, requires that evidence independent of a defendant’s confession be introduced that reasonably tends to prove the defendant committed the charged offense. The misdemeanor domestic assault charge against Appellant required proof that (1) Appellant intentionally inflicted or attempted to inflict bodily harm upon the victim; and (2) the victim was Appellant’s family or household member. Minn. Stat. §§ 609.02, subd. 10(2), 609.2242, subd. 1(2). Without Appellant’s confession, the State presented sufficient evidence reasonably tending to prove these elements. Thus, the district court properly denied Appellant’s motion for judgment of acquittal.
In denying Appellant’s motion, the district court necessarily determined there was sufficient evidence independent of Appellant’s confession to submit the charge to the jury. This decision, made under section 634.03, is within the district court’s purview. Thus, the court acted within its discretion when it declined to instruct the jury as to the need for independent evidence, because that determination was already made by the district court, and it is not the jury’s duty to make such an assessment. Appellant’s conviction is affirmed. State v. Mattson-McCarty, A24- 1948, 2025 WL 3703674 (Minn. Ct. App. Dec. 22, 2025).
Police searched Appellant’s vehicle during a traffic stop without a warrant after smelling the odor of marijuana inside. The search revealed ammunition, and Appellant was prohibited from possessing ammunition at that time. The searched occurred before State v. Torgerson, 995 N.W.2d 164 (Minn. 2023), in which the Supreme Court held that the odor of marijuana from a vehicle is insufficient on its own to establish probable cause for a search under the automobile exception to the warrant requirement. The district court granted Appellant’s motion to suppress evidence from the search, relying on Torgerson, but the Court of Appeals reversed, finding the good faith exception to the exclusionary rule rendered the evidence admissible.
The Supreme Court disagrees. The court finds that the vehicle search was unlawful, as it was supported by only the odor of marijuana, which was insufficient on its own to establish probable cause for a warrantless search. Thus, the exclusionary rule would generally prohibit admission of evidence obtained during the search.
The good faith exception to the exclusionary rule has been applied in Minnesota only if the officer acted in objectively reasonable reliance on binding precedent that specifically authorizes the officer’s behavior. Applicable precedent required the officer here to assess whether probable cause existed for a warrantless search after considering the totality of the circumstances. The officer did not do that, basing his search on only the odor of marijuana from Appellant’s vehicle. Thus, the good faith exception does not apply and the evidence from the vehicle search was properly excluded. State v. Douglas, A24-0385, 29 N.W.3d 187 (Minn. Sup. Ct. Dec. 24, 2025).