State of Minnesota v. Nicholas Norton Engel

Summary

The court held that evidence of a new crime committed in response to a state-constitutional violation is subject to the fruit-of-the-poisonous-tree analysis and the four-factor attenuation test. Applying that test, the court concluded that Engel’s vehicular flight was sufficiently attenuated from the unconstitutional traffic stop because the officer did not exploit or deliberately provoke the violation and Engel’s extended, voluntary flight constituted an intervening act. The evidence therefore did not require suppression, and the court affirmed.