Airport Mailroom Dog Sniff Didn't Violate 4th Amendment

Minnesota case law summary by Attorney Richard Clem: search and seizure.

State of Minnesota v. Corey Joel Eichers. MN search & seizure

Corey Joel Eichers was charged with two counts of a first-degree controlled substance crime. Prior to trial, he moved to suppress evidence of a package containing cocaine and methamphetamine that was opened by investigators in a mail area following a positive drug alert by a trained narcotics-detection dog. He argued that the detention of the package in the mail area, prior to the positive dog sniff, was an unreasonable seizure, and that the dog sniff was an unreasonable search of the package. The Stearns County District Court disagreed and denied the motion. The Minnesota Court of Appeals agreed, and Eichers then appealed to the Minnesota Supreme Court.

The high court held:

1. Removing a package from an airport mailroom conveyor belt and placing it on the floor to be sniffed by a narcotics-detection dog is not a seizure under either the Fourth Amendment to the U.S. Constitution or Article I, Section 10, of the Minnesota Constitution. The movement of the package did not constitute meaningful interference with the addressee’s possessory interests in the package.

2. There is no reasonable expectation of privacy when an officer conducts a minimally intrusive dog sniff of a package in an airport mailroom, and thus the dog sniff in this case was not a search for purposes of either the Fourth Amendment or Article I, Section 10, of the Minnesota Constitution.

3. Because neither a search nor a seizure occurred, there was no violation of either provision, regardless of whether the officer’s actions were reasonably justified.

Therefore, the district court did not err by denying the motion to suppress evidence, and the Supreme Court affirmed. No. A13-0121 (Minn. Sept. 10, 2014)

Please see the original opinion for the court's exact language.


Richard P. Clem is an attorney and continuing legal education (CLE) provider in Minnesota. He has been in private practice in the Twin Cities for 25 years. He has a J.D., cum laude, from Hamline University School of Law in St. Paul and a B.A. in History from the University of Minnesota. His reported cases include: Asociacion Nacional de Pescadores a Pequena Escala o Artesanales de Colombia v. Dow Quimica de Colombia, 988 F.2d 559, rehearing denied, 5 F.3d 530 (5th Cir. 1993), cert. denied, 510 U.S. 1041 (1994); LaMott v. Apple Valley Health Care Center, 465 N.W.2d 585 (Minn. Ct. App. 1991); Abo el Ela v. State, 468 N.W.2d 580 (Minn. Ct. App. 1991).

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