State of Minnesota v. Michael Allan Carbo, Jr.

Citations

• 6 N.W.3d 114

Syllabus

1. The district court did not err by denying the defendant's motion to suppress evidence stemming from a genetic analysis of DNA collected from crime scene materials because the defendant had abandoned his subjective expectation of privacy in that information by leaving his semen at the scene of the crime. 2. The district court did not err by denying the defendant's motion to suppress evidence stemming from a genetic analysis of DNA collected from his garbage because law enforcement lawfully and independently obtained identical information from a DNA sample the defendant voluntarily provided. 3. The district court abused its discretion by denying the defendant's motion to present alternative-perpetrator evidence because the defendant's proffered evidence clearly had an inherent tendency to connect the alternative perpetrator to the commission of the crime and could have been admitted under the ordinary rules of evidence, and the error was not harmless beyond a reasonable doubt. Reversed and remanded.