Garcia-Mendoza v. 2003 Chevy Tahoe, Minn.S.Ct., 8/20/2014. Procedurally, this is a messy, really messy case. The facts are reasonably straight forward, as is the holding of the court. In a few words, the exclusionary rule of the Fourth Amendment applies to forfeiture actions.
Police saw Mr. Garcia-Mendoza’s vehicle moving down I-94 at just a hair over the speed limit. The officer ran a a registration check for the vehicle but when the officer then ran a license check for the registered owner he got nothing back. The cop then stopped the vehicle in the belief that the driver didn’t have a valid driver’s license.
Which was correct, at least for Mr. Garcia-Mendoza and his passenger. Since no one could drive the car and it didn’t appear safe to the officer to leave the car on the break down lane of the interstate the officer called for a tow; alas, the inventory search incident to the two produced methamphetamine, a lot of it.
Both the state and the feds charged Mr. Garcia-Mendoza with drug crimes. Mr. Garcia-Mendoza moved in federal court to suppress the drugs as the fruit of an illegal stop and search. The federal court rejected that claim and thereafter Mr. Garcia-Mendoza pled guilty. As part of his plea he agreed to forfeit the vehicle.
Meantime, the state filed a forfeiture action against the vehicle. Mr. Garcia-Mendoza made the same objection, saying that the cops had discovered the legal justification for the forfeiture – the drugs – as a result of a violation of the Fourth Amendment. That meant that under the exclusionary rule the drugs should be suppressed at which point there was no longer a legal basis to grab the vehicle. The trial court upheld the forfeiture by pointing to Mr. Garcia-Mendoza’s federal plea agreement to allow just that forfeiture. As an aside, the trial court said that the stop and search of the vehicle had, indeed, violated the Fourth Amendment.
The court of appeals affirmed the district court, but not on the basis of the federal plea agreement. Rather, that court affirmed the district court by concluding that the exclusionary rule did not apply to forfeiture actions, and that the state statute presumed that the vehicle was to be forfeited, a presumption that Mr. Garcia-Mendoza did not rebut. There were other issues lurking in the bushes in both the trial court and court of appeals, but the supreme court plucked out only the applicability of the exclusionary rule for review.
Justice Dietzen somewhat regrettably it seems acknowledges that the court must follow a U.S. Supreme Court opinion from 1965 that said that the exclusionary rule of the Fourth Amendment applies to civil forfeiture actions brought under the federal forfeiture statute. One 1958 Plymouth Sedan v. Pennsylvania, 380 U.S. 693 (1965). The Justice, writing for the entire court, declines the state’s invitations to ignore this Plymouth Sedan case, invitations based upon the withering away of the exclusionary rule since 1965.
Having reached that conclusion, the court sends the case back to the court of appeals to sort through the detritus left along the side of the road, which include:
(1) appellant is collaterally estopped from relitigating the determination of the federal district court that the March 19 stop and search did not violate appellant’s Fourth Amendment rights; (2) appellant’s factual admissions in the federal guilty plea agreement in which he agreed to give up his rights to property obtained as a result of his drug trafficking offense provide an independent basis for forfeiture of the seized property; (3) appellant’s exclusive remedy to suppress the challenged evidence is Minn. Stat. § 626.21 (2012) (“A person aggrieved by an unlawful search and seizure may move . . . to suppress the use, as evidence, of anything so obtained . . .”), but appellant waived that remedy by not asserting it; and (4) the district court erred when it observed in dictum that the March 19 stop and search violated appellant’s Fourth Amendment rights.
These guys are just getting started. Start your engines, indeed.
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