State v. Dexter
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The Supreme Court affirmed the decision of the court of appeals reversing the district court's denial of Defendant's request for non-identifying information about a confidential reliable informant's relationship with police and the informant's information-gathering activities, holding that the State's common law privilege to withhold the identity of an informant does not protect non-identifying information.
Defendant was charged with drug possession and sale crimes. Defendant filed discovery and suppression motions seeking information about a confidential reliable informant, on whose observations the State relied to obtain a warrant to search Defendant's home. The district court denied the motions, concluding that Defendant was not entitled to discover the informant's identity or any other information about the informant. Defendant was convicted of fifth-degree sale of a controlled substance. The court of appeals reversed, holding that the State's common law privilege did not protect non-identifying information. The Supreme Court affirmed, holding that the court of appeals (1) properly concluded that the State's common law privilege does not apply to non-identifying information; and (2) did not err in concluding that the non-identifying information Defendant requested related to the case, as required by Minn. R. Crim. P. 9.01.
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