The Minnesota Supreme Court issued a ruling Tuesday in *State of Minnesota v. Brian Russell Lueck* that clarifies the requirements for test refusal convictions in DWI cases, holding that defendants must refuse the specific type of chemical test authorized by warrant to sustain a conviction under state law.

The court held that when a warrant authorizes one type of chemical test—either blood or urine—a person's refusal to submit to that specific test, and not another, is required to sustain a conviction for test refusal under Minnesota Statutes sections 169A.20, subdivision 2(2), and 171.177, subdivision 2. The decision addresses a constitutional challenge to the test-refusal statute as applied to drivers who refuse chemical tests where law enforcement obtained a warrant authorizing only one type of test.

Justice McKeig wrote the opinion for the court, with Justice Hennesy taking no part in the decision. The case arose from circumstances where Brian Russell Lueck challenged his test refusal conviction, arguing constitutional violations under the Fourth Amendment.

The constitutional question centered on whether prosecuting a driver for test refusal in cases where law enforcement obtained a warrant for a specific type of chemical test would violate Fourth Amendment protections. The court definitively answered this question in the negative, holding that a test refusal conviction based on refusal of a warranted chemical test does not violate the Fourth Amendment.

This ruling resolves uncertainty about the scope of Minnesota's test refusal laws when warrants specify particular testing methods. Under the court's interpretation, the specificity of the warrant matters—law enforcement cannot charge test refusal for declining a different type of test than what the warrant authorized.

The decision has implications for how DWI cases are prosecuted throughout Minnesota. Prosecutors must now ensure that test refusal charges align precisely with the type of chemical test authorized by the warrant. This means if a warrant authorizes blood testing, a defendant cannot be convicted of test refusal for declining a urine test, and vice versa.

The case involved the intersection of two key statutory provisions. Minnesota Statute section 169A.20, subdivision 2(2), governs the general test refusal offense, while section 171.177, subdivision 2, specifically addresses testing pursuant to a search warrant. The court's ruling clarifies how these statutes work together when law enforcement seeks warrants for specific types of chemical tests.

The Fourth Amendment analysis focused on whether offering a test not authorized by the warrant would implicate constitutional protections. The court determined that the warrant requirement itself provides sufficient Fourth Amendment protection, and that test refusal convictions based on warranted tests do not create constitutional violations.

This decision provides clarity for law enforcement agencies across Minnesota about warrant specificity requirements. Officers must now ensure that the chemical tests they offer to suspected impaired drivers match exactly what their warrants authorize. This could affect how warrants are written and how test refusal cases are prosecuted.

The ruling also impacts defense strategies in DWI cases. Defense attorneys can now argue that test refusal charges should be dismissed if prosecutors cannot prove their clients refused the specific type of test authorized by the warrant. This creates a new avenue for challenging test refusal convictions based on warrant specificity.

For drivers facing DWI charges, the decision means that the specific language of search warrants becomes more critical. The type of chemical test specified in the warrant determines what test refusal charges can be sustained, providing a more precise framework for understanding legal obligations.

The case was argued by Keith Ellison, Minnesota Attorney General, along with Wadena County Attorney Kyra Ladd and Special Assistant County Attorney Scott A. Hersey representing the state. Appellant Lueck was represented by Charles A. Ramsay and Daniel J. Koewler of Ramsay Law Firm.

The decision reflects the court's careful balance between law enforcement needs and constitutional protections in DWI cases. By requiring warrant specificity while upholding the constitutionality of test refusal prosecutions, the court provides guidance that strengthens both prosecution and defense positions in different circumstances.

This ruling will likely influence how lower courts interpret test refusal cases and may prompt legislative review of current DWI testing statutes. The decision provides clearer guidelines for prosecutors, defense attorneys, and law enforcement about the relationship between warrant specificity and test refusal convictions in Minnesota DWI cases.