holding that “Minnesota’s implied-consent statute does not violate the unconstitutional-conditions doctrine by authorizing the commissioner of public safety to revoke the driver’s license of a person who has been arrested for DWI and has refused to submit to chemical testing”
How later courts described this case
- holding that “Minnesota’s implied-consent statute does not violate the unconstitutional-conditions doctrine by authorizing the commissioner of public safety to revoke the driver’s license of a person who has been arrested for DWI and has refused to submit to chemical testing”
- concluding that a warrantless search under the implied-consent statute would not violate the Fourth Amendment but expressly limiting that conclusion to "a civil action in which [driver sought] to rescind the temporary revocation of her driver's license"
- holding that the implied-consent statute does not place an unconstitutional condition upon the exercise of Fourth-Amendment rights
- holding that Minnesota Implied Consent Law does not violate the unconstitutional-conditions doctrine
Written by the judges who cited it.
The opinion
CHUTICH, Judge
(concurring specially).
I agree with the majority’s conclusion that sufficient evidence supports the district court’s finding that Stevens refused to submit to chemical testing and that her unconstitutional-conditions argument fails. I write separately concerning the unconstitutional-conditions discussion because I would base my rejection of that doctrine solely on the rationale stated in Part D of *732 the majority’s opinion. I agree with the majority that the Minnesota Supreme Court’s decision in State v. Brooks, 838 N.W.2d 563 (Minn.2013), cert. denied, — U.S. -, 134 S.Ct. 1799 , 188 L.Ed.2d 759 (2014), prevents Stevens from establishing that the implied-consent statute coerced her into surrendering her Fourth Amendment right in a way that offends the unconstitutional-conditions doctrine.