27. Do Not Exclude All Drug Tests By the St. Paul Crime Lab.

Chief Justice Lorie Skjerven Gildea wrote for the Supreme Court in rejecting a blanket policy of excluding drug evidence handled by the Crime Laboratory of the St. Paul Police Department.

2015-152*       State of Minnesota, Respondent, vs. Richard Ellis Hill, Appellant.

This case presents the question of whether we should adopt a rebuttable presumption of contamination for controlled substances that the St. Paul Police Crime Lab (“Crime Lab”) handled and that the Minnesota Bureau of Criminal Apprehension (“BCA”) later tested.  See here. 

The State charged appellant Richard Ellis Hill with aiding and abetting first-degree sale of a mixture of a controlled substance of ten grams or more, in violation of Minn. Stat. § 155.021, subd. 1(1) (2014), in connection with the sale of methamphetamine.  Hill waived his right to a jury and submitted his case to the court. 

During the court trial, Hill objected to the admission of the BCA results that confirmed that the substance was methamphetamine.  Hill argued the BCA test results were unreliable because the contents of the bags might have been contaminated while the bags were in the custody of the Crime Lab, which was investigated for deficiencies in its quality-assurance controls. 

Applying a chain-of-custody analysis, the district court rejected Hill’s contamination argument.  Hill was subsequently convicted of the charged offense. 

The court of appeals affirmed, State v. Hill, No. A13-1803, 2014 WL 6608809, at 5 (Minn. App. Nov. 24, 2014), and we granted review. 

Unlike Scales and Lefthand, the issue at hand does not present statewide implications.  Instead, it is limited to a single testing laboratory.  Furthermore, in both Scales and Lefthand, we acted in response to the State’s refusal to heed admonitions with respect to matters we had identified as necessary for the vindication of a criminal defendant’s rights.  Scales, 518 N.W.2d at 592; Lefthand, 488 N.W.2d at 801-02.  Hill, on the other hand, has not offered any evidence to suggest that the Crime Lab persisted in substandard operations despite our warnings.  See State v. Dominguez-Ramirez, 563 N.W.2d 245, 257 (Minn. 1997) (refusing to exercise our supervisory powers where the State had not “deliberately ignore[d] our prior directives”).  Additionally, the Legislature has since taken action to address the concerns of substandard crime lab operations.  See Minn. Stat. § 299C.157 (2014).  Accordingly, we conclude that the invocation of our supervisory powers to adopt the requested presumption of contamination is not required to ensure the fair administration of justice.

Our holding today should not be read to condone in any way the Crime Lab’s past operations.  Rather, our holding reflects only that the conduct at issue in this case did not rise to the exacting level of a substantive due process violation or necessitate the presumption of contamination that Hill requests.

Affirmed

Gildea (Anderson, Dietzen, Stras, Wright, and Lillehaug)

Took no part:  Hudson

[GILDEA] [DRUGS] [EVIDENCE]

A13-1803,