CRIMINAL LAW
Search warrants

State of Minnesota v. Ivan Contreras-Sanchez No. A22-1579 (Minn. April 15, 2026)

The facts: After officers were notified that a body had been found in a drainage culvert, they applied for a geofence warrant, which identifies mobile devices active within a specific area during a set timeframe. They requested location-history data from Google for devices near the culvert over the previous month.

The warrant application outlined a three-step process for law enforcement to obtain the data from Google. In step one, Google would provide anonymous device identification numbers for all data points within the geofence. In step two, law enforcement would analyze that data to identify users who may have witnessed the crime. Google would then provide additional location history outside the defined area for those devices identified by law enforcement. In step three, officers would analyze the step-two data and require Google to identify the subscribers linked to relevant accounts.

Data from Google showed one device in the area for about 10 minutes. Step-two data indicated the device had been at a nearby gas station shortly before arriving at the scene. Officers reviewed surveillance video from the gas station and identified a person of interest. They then executed step three of the warrant, identifying the suspect as Ivan Contreras-Sanchez.

The type of case: Before trial, Contreras-Sanchez moved to suppress all evidence obtained through the geofence warrant. The district court denied the motion. A jury later found him guilty of second-degree murder. On appeal, he argued that geofence warrants are unconstitutional and that this specific warrant was not sufficiently particular, violating the U.S. and Minnesota constitutions. The Court of Appeals affirmed the district court’s denial of the defendant’s motion to suppress. The Minnesota Supreme Court granted review to address the constitutionality of geofence warrants.

The issues: The Minnesota Supreme Court considered whether geofence warrants are prohibited as general warrants, which are overbroad searches that the Constitution strictly forbids. The court also weighed whether probable cause supported the geofence warrant in this case and whether it was sufficiently particular, meaning it was narrowly tailored to a specific place, time, and person.

The court’s ruling: Relying on the Minnesota Constitution, the court held that individuals have a reasonable expectation of privacy in cell phone location data stored by Google. Even when users opt in to share that data, the court found the consent is not a fully informed. As a result, law enforcement must obtain a warrant to access such information.

The court also determined that geofence warrants are not inherently unconstitutional general warrants. A general warrant fails to describe the place to be searched with particularity and allows exploratory searches. Geofence warrants may be valid if reviewed on a case-by-case basis for probable cause. In this case, the court determined there was probable cause to issue the geofence warrant based on information obtained from an informant.

Finally, the court analyzed whether the geofence warrant was sufficiently particular to the area in question. It held that step one adequately described the place to be searched and the relevant time frame. However, steps two and three were not sufficiently particular because they did not meaningfully limit police discretion in selecting which devices to investigate further. The court noted the geofence warrant lacked safeguards to prevent officers from treating every device in the geofence as a suspect and broadly reviewing additional location data.

What this means for cities: When seeking geofence warrants, officers must provide specific, individualized criteria that limit discretion when reviewing additional data. A similar case was heard at the U.S. Supreme Court on April 27, 2026. While Minnesota’s decision was based solely on the Minnesota Constitution, a future Supreme Court ruling could affect this area of law.

WORKERS’ COMPENSATION
Special-errand exception

Ludwig v. Dakota County, No. A24-1989 (Minn. April 22, 2026)

The facts: Cindy Ludwig worked for Dakota County performing full-time clerical and customer service duties at its Hastings office. In March 2020, the county issued a stay-at-home order due to the COVID-19 pandemic, requiring Ludwig to work from home full time. Ludwig brought her work equipment home from the office. In September 2021, the county required employees to return to working in the office. While loading her equipment into her vehicle to return to the office, Ludwig fell and injured her back. She sought medical treatment and returned to work a week later.

The type of case: Ludwig filed a claim for workers’ compensation benefits, and the matter came before a workers’ compensation judge. Although injuries sustained while commuting are generally not compensable, Ludwig argued her injury qualified under the special-errand exception because it occurred while she was loading equipment at her employer’s direction. The compensation judge concluded the special-errand exception did not apply because Ludwig was returning her equipment as part of her commute. An appeals court determined the special-errand exception should apply. The county appealed to the Minnesota Supreme Court.

The issues: The court analyzed whether the special-errand exception applied to Ludwig’s injury.

The court’s ruling: Injuries sustained while traveling to and from work are generally not compensable under the Workers’ Compensation Act. However, the special-errand exception applies when an employee is injured while carrying out a special task or performing a special mission for the employer. The court ruled that the county’s return-to-office directive implicitly required Ludwig to transport her equipment back to the workplace. As a result, she was performing a special errand when she was injured, and the injury was compensable. The court noted that in a hybrid work setting, not every instance of transporting work equipment during a commute will qualify as a special errand. This case, however, involved more than a routine commute.

What this means for cities: While employees are not covered by the Workers’ Compensation Act during their regular commute, they are covered when performing special errands. Cities should remind employees to follow safety precautions when performing off-site duties.

EMPLOYMENT LAW
Whistleblower protection

Woods v. City of St. Louis No. 24-2689 (8th Cir. App., March 30, 2026)

The facts: Angelica Woods, a former City of St. Louis corrections officer, began working as a clerk for the city’s towing service division. She developed concerns about the tow lot’s operations. Woods was told that she could get inexpensive vehicles from the lot for herself and her family by changing a vehicle’s sale price and obtaining a new title for the vehicle. She also observed vehicles being sold without going to auction.

Woods reported her concerns to her supervisor, the director of the streets department, the mayor’s office, and eventually the media. She was labeled a snitch and marginalized because of her refusal to participate in the unlawful activities. The day after a news story aired about the situation, Woods was fired.

The type of case: Woods sued the city claiming it unlawfully retaliated against her for exercising her First Amendment rights. A jury found in her favor, awarding $207,612 in compensatory damages and $50,000 in punitive damages. The city appealed.

The issues: The court analyzed whether there was sufficient evidence to support the jury’s finding that Woods was terminated for exercising her First Amendment rights.

The court’s ruling: The court ruled there was ample evidence to support the jury’s findings. It pointed to evidence of workplace conflict Woods had with other employees and supervisors, as well as the timing of the termination in relation to the news report. The jury also heard evidence that another employee was terminated after reporting the same illegal activities. The court, upheld the jury’s verdict.

What this means for cities: Termination of city employees should be based on performance, not retaliation. Cities should ensure employees are not penalized for reporting wrongdoing or exercising First Amendment rights.

Written by Kyle Hartnett, assistant research manager with the League of Minnesota Cities. Contact: [email protected] or (651) 215-4084.