Nash v. Commissioner of Public Safety
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The case revolves around the interpretation of Minnesota Statutes section 171.177, subdivision 1, which requires law enforcement officers to inform individuals suspected of driving under the influence that refusal to submit to a blood or urine test is a crime. The respondent, Brian Matthew Nash, was pulled over for suspected impaired driving. After failing field sobriety tests, he was arrested and a state trooper obtained a search warrant for a blood or urine test. The trooper informed Nash that refusal to take a test is a crime, and Nash complied. His blood test revealed the presence of a controlled substance, leading to the revocation of his driving privileges.
Nash sought judicial review of his license revocation, arguing that the trooper's advisory did not comply with the statutory requirement. The district court rejected Nash's arguments and sustained the revocation. On appeal, the court of appeals reversed, finding that the advisory given to Nash was misleading and an inaccurate statement of law.
The Minnesota Supreme Court disagreed with the court of appeals' interpretation of the statute. The court held that the trooper's statement that "refusal to take a test is a crime" satisfied the advisory required by section 171.177, subdivision 1. The court reasoned that the statute does not require officers to inform drivers of all the elements and permutations of what is required before the state may take adverse action against them. The court reversed the decision of the court of appeals and remanded the case for consideration of the other issues raised by Nash in his appeal.
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