State of Minnesota vs. Malecha
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In Minnesota, a defendant, Rebecca Julie Malecha, was arrested on a warrant that had been quashed but was still appearing as active in law enforcement databases due to a clerical error by court administration. During the arrest, police discovered controlled substances on Malecha's person and charged her with four controlled substance crimes. Malecha moved to dismiss the charges, arguing the search was unconstitutional due to the quashed warrant. The district court granted her motion, based on the violation of Article I, Section 10, of the Minnesota Constitution, but the court of appeals reversed this decision.
The Minnesota Supreme Court reversed the court of appeals, holding that the good-faith exception to the exclusionary rule does not apply to evidence obtained during a search on a quashed warrant that appears active to law enforcement because of a clerical error by court administration. The court reasoned that applying the exclusionary rule would serve to deter unlawful government conduct generally, not just police misconduct. The court emphasized that the benefits of excluding illegally obtained evidence outweighed the costs in this case, particularly in situations where the constitutional violation stemmed from a court clerical error. Therefore, the charges against Malecha were dismissed.
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