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Minnesota v. Seneca Warrior Steeprock

Paid petition · Supreme Court of Minnesota, No. A23-0875 · judgment December 18, 2025


Certiorari denied · June 8, 2026
Pre-decision estimate: 1% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

In Nix v. Williams, 467 U.S. 431 (1984), this Court established the inevitable-discovery doctrine as an exception to the exclusionary rule. Under that doctrine, the exclusionary rule does not apply if the prosecution can establish that evidence unlawfully seized would have inevitably been discovered by lawful means. Since Nix, the lower courts have deeply divided over what “inevitably” means in this context. The question presented is: Does the inevitable-discovery doctrine require proof that law enforcement was actively pursuing a warrant or an alternative line of investigation at the time of the challenged conduct, or does the doctrine apply when objective, demonstrated historical facts establish that the evidence would have been lawfully obtained through ordinary and predictable procedures?

Counsel of record

For petitioner
Thomas R. Ragatz
Minnesota Attorney General's Office

For respondent
Benjamin Jon Butler
Minnesota Appellate Public Defender's Office

Case

Conference history
Distributed for 1 conference

Linked docket
25A1010

Proceedings

  1. Jun 08 2026
    Petition DENIED.
  2. Jun 08 2026
    Motion for leave to proceed in forma pauperis filed by respondent GRANTED.
  3. May 19 2026
    DISTRIBUTED for Conference of 6/4/2026.
  4. May 14 2026
    Reply of petitioner Minnesota filed.
  5. Apr 30 2026
    Motion for leave to proceed in forma pauperis filed by respondent Seneca Warrior Steeprock.
  6. Apr 30 2026
    Brief of respondent Seneca Warrior Steeprock in opposition filed.
  7. Apr 16 2026
    Petition for a writ of certiorari filed. (Response due May 22, 2026)
  8. Mar 18 2026
    Reply to opposition to application for extension of time to file petition for writ of certiorari submitted.
  9. Mar 17 2026
    Application (25A1010) granted by Justice Kavanaugh extending the time to file until April 16, 2026.
  10. Mar 13 2026
    Opposition to application for extension of time from respondent Seneca Warrior Steeprock filed.
  11. Mar 06 2026
    Application (25A1010) to extend the time to file a petition for a writ of certiorari from March 16, 2026 to April 16, 2026, submitted to Justice Kavanaugh.