Supreme Court of Minnesota

State of Minnesota v. Raenard Romalle Douglas

December 24, 2025

Summary

The court held that the good-faith exception does not save ammunition discovered during a warrantless vehicle search based solely on the smell of marijuana. Although the search occurred before controlling precedent expressly rejected odor alone as probable cause, earlier authority did not specifically authorize this search and intervening decisions had made the law unsettled. The court therefore reversed the court of appeals and remanded for further proceedings.