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State v. Dreyer

Supreme Court of Minnesota
Mar 16, 1984
345 N.W.2d 249 (Minn. 1984)

Summary

holding that police did not violate defendant's fourth amendment rights in seizing and searching three plastic bags full of garbage which defendant had put out for collection at the curb at the edge of his driveway

Summary of this case from State v. Krech

Opinion

No. C3-82-1499.

March 16, 1984.

Appeal from the District Court, Blue Earth County, Miles B. Zimmerman, J.

Douglas W. Thomson, St. Paul, for appellant.

Hubert H. Humphrey, III, Atty. Gen., St. Paul, David Twa, Asst. County Atty., Mankato, for respondent.

Considered and decided by the court en banc without oral argument.


Defendant was found guilty in district court of possession of marijuana and possession of marijuana with intent to sell and was sentenced to pay a fine and to serve a prison sentence. Execution of the sentence was stayed, and defendant was placed on probation with conditions. We affirm.

Defendant raises a number of fourth amendment issues on appeal, some of them contingent on our deciding the issue of the validity of a so-called garbage search in defendant's favor. The garbage search was conducted without a warrant an February 25, 1982, and involved the search of garbage which had been placed on the curb for routine collection. Search of the garbage resulted in the discovery of marijuana residue, which in turn led to the issuance of a warrant to search the "premises" described as "110 South Western Avenue, a two-story white wood frame house with green trim." The issue of the validity of the garbage search is controlled by State v. Oquist, 327 N.W.2d 587 (Minn. 1982), where we held on similar facts that the police there did not violate the defendant's fourth amendment rights.

Defendant's remaining contention is that the police exceeded the scope of the subsequently-issued warrant in searching the garage attached to defendant's house, the garage being where the police found the marijuana. We hold that the garage was part of the "premises" described in the warrant. This holding is consistent with cases from other jurisdictions. The cases are collected at 2 W. LaFave, Search and Seizure § 4.10(a) (1978).

Affirmed.


Summaries of

State v. Dreyer

Supreme Court of Minnesota
Mar 16, 1984
345 N.W.2d 249 (Minn. 1984)

holding that police did not violate defendant's fourth amendment rights in seizing and searching three plastic bags full of garbage which defendant had put out for collection at the curb at the edge of his driveway

Summary of this case from State v. Krech

holding that garage constitutes part of "premises" described in search warrant for subject resident’s apartment

Summary of this case from State v. Hill

holding that police did not violate defendant's Fourth Amendment rights in seizing and searching three plastic bags full of garbage which defendant had put out for collection at the curb at the edge of his driveway

Summary of this case from State v. Rump

holding that police did not violate a defendant's Fourth Amendment rights by searching garbage left at curb

Summary of this case from State v. Higgins

holding police did not violate defendant's Fourth Amendment rights by seizing and searching garbage left at curb

Summary of this case from State v. McMurray

holding police did not violate defendant's Fourth Amendment rights in seizing and searching garbage left at curb at the edge of driveway

Summary of this case from State v. Birdsall

finding a search warrant valid when based solely on marijuana residue retrieved during a residential garbage search

Summary of this case from State v. Horbach

finding that warrantless search of garbage can placed on curb for routine collection did not violate Fourth Amendment

Summary of this case from State v. Horbach

finding that warrantless search of garbage can placed on curb for routine collection did not violate Fourth Amendment

Summary of this case from State v. Pedersen

concluding police did not violate defendant's Fourth-Amendment rights in seizing and searching three plastic bags full of garbage that defendant had put out for collection at curb at end of his driveway

Summary of this case from State v. Holmberg

noting that marijuana residue in garbage supported a search warrant for the house

Summary of this case from State v. Erdmann
Case details for

State v. Dreyer

Case Details

Full title:STATE of Minnesota, Respondent, v. Raymond H. DREYER, Appellant

Court:Supreme Court of Minnesota

Date published: Mar 16, 1984

Citations

345 N.W.2d 249 (Minn. 1984)

Citing Cases

State v. Goebel

However, when a police officer searches trash, set on the curb for routine pickup, without trespassing on the…

State v. McGrath

In State v. Dreyer, marijuana residue retrieved during a residential garbage search led to the issuance of a…