State of Minnesota v. Lyndon Akeem Wiggins

Summary

The court upheld the denial of Wiggins's motion to suppress cell-site location information because the warrant application, considered under the totality of the circumstances, established a fair probability that the records would contain evidence of a crime. The court nevertheless reversed his convictions because the jury instructions allowed conviction based on another person's satisfaction of the offense elements without requiring the jury to determine Wiggins's criminal liability for that person's conduct. The instructional error was not harmless beyond a reasonable doubt, so the case was remanded for further proceedings.