Unlawful Arrest: Legal Remedies

Estimated reading time: 15 minutes

An arrest is a pivotal event.

What is an arrest? First, it is a person surrendering their liberty under someone’s threat or use of force. So it is the use of force or the threat of the use of force.

Next, an arrest is a loss of liberty. Liberty includes the right to self-control, and to go wherever one may lawfully go. The word arrest as a noun and verb for “stopping” or “delaying,” originates from the 14th-century Anglo-Norman word arest or arester, meaning “to stop, stay, or restrain,” from the Latin ad restare “to stand still.”

This loss of liberty could be the result of state action. But a private party can also arrest a person for example in the case of a security guard or a citizen arrest.

And an arrest might be lawful, for example by a police officer or by a citizen. Or an it might be unlawful, an assault or false imprisonment. If unlawful, the person wronged may have a remedy available.

Remedies to an unlawful arrest may include:

1. Fleeing,
2. Physically resisting with reasonable force,
3. Habeas Corpus Petition,
4. Motion to Suppress Evidence as Illegal,
5. Motion to Dismiss Criminal Charges,
6. Civil Litigation for Damages.

The focus of this article is on arrests and criminal law.

Fourth Amendment

“The right of the people to be secure in their persons , houses , papers , and effects, against unreasonable searches and seizures, shall not be violated, and no warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.”

Fourth Amendment, United States Constitution

The Fourth Amendment’s protection against “unreasonable . . . seizures” includes seizure of the person. The United States Supreme Court explains:

“An arrest requires either physical force (as described above) or, where that is absent, submission to the assertion of authority.

‘Mere words will not constitute an arrest, while, on the other hand, no actual, physical touching is essential. The apparent inconsistency in the two parts of this statement is explained by the fact that an assertion of authority and purpose to arrest followed by submission of the arrestee constitutes an arrest. There can be no arrest without either touching or submission.’ Perkins, The Law of Arrest, 25 Iowa L. Rev. 201, 206 (1940).”

California v. Hodari, 499 US 621 (US Supreme Court 1991)

Minnesota Constitution

“The right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures shall not be violated; and no warrant shall issue but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched and the person or things to be seized.”

Article I, Sec. 10, Minnesota Constitution. Unreasonable searches and seizures prohibited.

A person in Minnesota possesses rights recognized under the United States Constitution. But that person may possess greater rights and more protection under the Minnesota Constitution.

The Minnesota Court of Appeals explains:

“The Minnesota Supreme Court has interpreted article I of the Minnesota Constitution to offer more protection than the Fourth Amendment to the United States Constitution. For example, although California v. Hodari D., 499 U.S. 621 (1991) held that a seizure occurs when police use physical force or when a person submits to a show of authority, the Minnesota Supreme Court determined that under the Minnesota Constitution, a person could be seized even in the absence of force, if a reasonable person would not feel free to leave under the totality of the circumstances. In re Welfare of E.D.J., 502 N.W.2d 779, 783 (Minn. 1993) (“[W]e are not persuaded by the majority opinion in Hodari, and we are persuaded that there is no need to depart from the pre-Hodari approach.”); see also State v. Askerooth, 681 N.W.2d 353, 363 (Minn. 2004) (declining to adopt the holding in Atwater v. City of Lago Vista, 532 U.S. 318 (2001), and instead applying Terry v. Ohio, 392 U.S. 1, 19-21 (1968)).”

State v. Carr, nonprec A20-1183 (Minn. Court of Appeals 2021), fn 4

Those courts explain how judges distinguish an arrest from something less. And that is one important consideration when deciding whether it was unlawful. The officer must know objective facts at the time of the arrest to justify it as lawful.

Warrant vs. Warrantless Arrest

An arrest warrant is a judicial order authorizing a law enforcement officer to seize and detain a person and hold them in custody. The reason could be a new criminal charge supported by a claim under oath supporting probable cause to believe the defendant committed a crime. Or the basis could be a missed court appearance, or failure to appear. But because police acting under the authority of an arrest warrant are administratively executing a judge’s decision, only in unusual circumstances would a court find such an arrest without lawful basis.

As a result, most unlawful arrests are warrantless. And so this article will focus on warrantless arrests.

“Robinson was in custody to the degree associated with formal arrest when Deputy Z.S. informed him that there was an outstanding warrant for his arrest, Robinson confirmed that he was aware of the arrest warrant, and law enforcement handcuffed and walked him to a squad car. Despite Deputy Z.S.’s statement that he was ‘just going to detain Robinson’ until he received confirmation of the warrant’s validity, we conclude based on all the surrounding circumstances that an objectively reasonable person in Robinson’s place would have believed that they were in custody. Cf. Olson, 634 N.W.2d at 229 (concluding a reasonable person in the defendant’s position would have believed that he was under arrest when the defendant was told that he was “under arrest,” handcuffed, and subjected to a pat-down search before being placed in a squad car).”

State v. Robinson, nonprec A25-0850 (Minn. Court of Appeals 2025)

Arrest vs Temporary Detention

Traditionally an arrest was simply any deprivation of liberty accomplished by force or the threat of force. Either you were free and at liberty, or someone had arrested you by force or under threat of force. But constitutional law has developed over time to create an intermediate category where a person has been seized by force or threat of force, but is not afforded the legal protections required for an arrest. They call this intermediate condition a temporary detention, which includes circumstances where the seized person is only briefly detained and the intrusiveness of the detention is extremely slight.

As a result defense attorneys analyze the fact of every case for lack of legal justification for these three legal categories:

1. initial seizure or stop,
2. expansion of the length, scope or intensity of the stop or detention, and
3. probable cause for the arrest.

If any of these lack facts to legally justify them, a judge should suppress the evidence illegally obtained as a result.

A police officer may not make a warrantless arrest of a person without probable cause that the person “had committed or was committing an offense.” Beck v. Ohio, 379 U.S. 89, 91 (1964). But a law-enforcement officer may temporarily detain a person for investigatory purposes if the officer has a reasonable, articulable suspicion that the person has engaged in criminal activity. Terry v. Ohio, 392 U.S. 1, 19-21 (1968); State v. Diede, 795 NW2d 836, 842-43 (Minn. 2011). More:

Illegal Stop by Police

Expansion of the Stop | Prolonged, Intrusive

No Need for “You Are Under Arrest”

Courts often use the term “formal arrest” without defining the term. They use the term within the context of attempting to delineate precisely when an arrest happens in various fact patterns. Presumably a formal arrest would include at the latest the moment a police officer chooses to say “you are under arrest,” should they ever choose to do so. But it often occurs before that. And that moment is important, since it requires objective facts at or prior to the time, amounting to probable cause for the officer to believe that the person committed a crime.

A de facto arrest may occur when a person was not formally arrested but was effectively arrested because their liberty was restrained beyond the scope of a lawful Terry stop. See, United States v. Sharpe, 470 U.S. 675, 682-88 (1985). The United States Supreme Court notes that the analysis may involve “difficult line-drawing problems in distinguishing an investigative stop from a de facto arrest.” Id. at 685; see also, Florida v. Royer, 460 U.S. 491, 506 (1983) (fact-specific nature of “determining when a seizure exceeds the bounds of an investigative stop”).

“Am I Free to Go?”

The Minnesota Supreme Court said that an arrest occurred if “a reasonable person would have concluded, under the circumstances, that he was under arrest and not free to go.” State v. Beckman, 354 NW2d 432, 436 (Minn. 1984). The supreme court later said that an arrest does not occur unless the person reasonably believes that he is both under arrest and not free to leave because “a person who is being detained temporarily is not free to leave during the period of detention, yet that does not convert the detention into an arrest.” State v. Moffatt, 450 NW2d 116, 119-20 (Minn 1990). The reasonable person standard is an objective standard ensuring that the scope of the constitutional protection against unreasonable searches and seizures does not vary with a person’s subjective state of mind, whether the officer or the person seized. More on the reasonable person standard:

The “Reasonable Person”.

Time and Force

When does a temporary detention, which must be justified by reasonable articulable suspicion of criminal activity under Terry, eventually turn into an arrest, which must be justified by probable cause? Two factors are key. First, is time. And second is the level of intrusiveness or force.

Handcuffing

And one common marker in the level of intrusiveness category is handcuffing. Usually when police handcuff a person, that signals both a formal and an effective, de facto arrest. Not only are you not free to leave, you can’t move your hands. But Minnesota courts have found in exceptional cases that a person was not arrested even after being handcuffed. So even that is not a bight line. The courts will engage in a balancing test.

And a key factor, perhaps the most important factor for the government justifying a greater use of force or intrusiveness is police officer safety. Are there objective facts that the government can point out to support the idea that the citizen-police contact presented an unusual risk of violence to police?

The de-facto-arrest test requires that a reasonable person at the time would believe he was under arrest, based on the scope, means and duration of the intrusion on the their liberty. In one case, the Minnesota Supreme Court approved of the use of handcuffs during an investigative detention for the purpose of ensuring officer safety. State v. Munson, 594 NW 2d 128 (Minn. Supreme Court 1999) (stop late at night, involving multiple suspects, information they may be armed, all were handcuffed until determined not armed and then handcuffs removed.) Whether an officer made a de facto arrest by placing a suspect in handcuffs may depend upon whether the officer was justified in believing that the suspect might have been armed and dangerous, and also on an assessment of the scope, means, and duration of the person’s detention.

Courts have delineated several situations when an arrest occurs. First, ordering a suspect to the ground and then handcuffing them constitutes an arrest. State v. Carver, 577 N.W.2d 245, 247-48 (Minn. App. 1998). Second, when police block a suspect’s parked car, order the person out of that car with guns drawn, and conduct a pat-search, a reasonable person would believe they were under arrest. State v. Rosse, 478 N.W.2d 482, 486 (Minn. 1991). Lastly, our supreme court has held that a “de facto” arrest occurs when police handcuff a suspect, place the suspect in a squad car, and do not allow the suspect to leave. State v. Blacksten, 507 N.W.2d 842, 847 (Minn. 1993).

Blawat v. Huener, nonprec A19-0605 (Minn. Court of Appeals 2020)

This case from the federal Eighth Circuit Court of Appeals notes:

“A de facto arrest occurs when the officer’s conduct is more intrusive than necessary for an investigative stop … We must consider such factors as the duration of a stop, whether the suspect was handcuffed or confined in a police car, whether the suspect was transported or isolated, and the degree of fear and humiliation that the police conduct engenders.”

US v. Hill, 91 F3d 1064 (US 8th Cir. 1996)

Who May Lawfully Arrest?

Minnesota Statutes authorize arrests by:

1. Police officers, Minn. Stat. §§ 626.862, 629.30, 629.32,
2. Federal law enforcement officers, Minn. Stat. § 626.77,
3. Private person, Minn. Stat. §§ 629.30, 629.37, 629.38, 629.39,
4. Merchant or merchant’s employee, Minn. Stat. § 629.366.

But arrest without lawful authority is a crime, if a public officer or pretending to be one:

“It is a gross misdemeanor for a public officer, or one pretending to be a public officer, knowingly and under the pretense or color of any process (1) to arrest a person or detain a person against the person’s will, (2) to seize or levy upon any property, or (3) to dispossess any one of lands or tenements, without a regular process for those actions.”

Minn. Stat. § 629.402

Statutory Limits on Arrests

In addition to Constitutional limits on legal authority, Minnesota Statutes limit powers as well. Minnesota Statutes Section 629.34 limits when arrests may be lawfully made without a warrant. It might be unlawful if outside of a police officer’s jurisdiction. In some situations, a part-time police officer might not be able to make a lawful arrest under the statute. More limits appear in subdivision 1 (c):

“(c) A peace officer or part-time peace officer who is authorized under paragraph (a) or (b) to make an arrest without a warrant may do so under the following circumstances:

(1) when a public offense has been committed or attempted in the officer’s presence;

(2) when the person arrested has committed a felony, although not in the officer’s presence;

(3) when a felony has in fact been committed, and the officer has reasonable cause for believing the person arrested to have committed it;

(4) upon a charge based upon reasonable cause of the commission of a felony by the person arrested;

(5) under the circumstances described in clause (2), (3), or (4), when the offense is a gross misdemeanor violation of section 609.52 [theft], 609.595 [Damage to Property], 609.631 [Check Forgery], 609.749 [Harassment, Stalking], or 609.821 [Financial Transaction Card Fraud];

(6) under circumstances described in clause (2), (3), or (4), when the offense is a nonfelony violation of section 518B.01, subdivision 14 [Violation of Order for Protection]; 609.748, subdivision 6 [Violation of Harassment Restraining Order]; or 629.75, subdivision 2, or a nonfelony violation of any other restraining order or no contact order previously issued by a court;

(7) under the circumstances described in clause (2), (3), or (4), when the offense is a gross misdemeanor violation of section 609.485 and the person arrested is a juvenile committed to the custody of the commissioner of corrections; or

(8) if the peace officer has probable cause to believe that within the preceding 72 hours, exclusive of the day probable cause was established, the person has committed nonfelony domestic abuse, as defined in section 518B.01, subdivision 2, even though the assault did not take place in the presence of the peace officer.”

Minn. Stat. § 629.34, Subd. 1

The above statute include the current Minnesota version of the “misdemeanor presence rule,” which generally requires that a law enforcement officer must witness a misdemeanor offense to make a warrantless arrest. However, that “rule” is riddled with exceptions, which are detailed in the statute.

Court Rule Limits on Arrest and Detention

The Minnesota Supreme Court has adopted the Minnesota Rules of Criminal Procedure, including Rule 4.02 and Rule 6.01:

“Following an arrest without a warrant:

Subd. 1. Release by Arresting Officer. If the arresting officer or the officer’s superior determines that further detention is not justified, the arrested person must be immediately released.
Subd. 2. Citation or Tab Charge. The arresting officer or the officer’s superior may issue a citation and release the arrested person, and must release the arrested person if ordered by the prosecutor or by a judge of the district court where the alleged offense occurred. The arresting officer or the officer’s superior may issue a citation or tab charge and continue to detain the arrested person if any of the circumstances in Rule 6.01, subd. 1(a)(1)-(3) exist.”

Rule 4.02, Minn. Rules of Crim. Pro.

And:

“Mandatory Citation Issuance in Misdemeanor Cases.
(a) By Arresting Officer. In misdemeanor cases, peace officers who decide to proceed with prosecution and who act without a warrant must issue a citation and release the defendant unless it reasonably appears:

(1) the person must be detained to prevent bodily injury to that person or another;

(2) further criminal conduct will occur; or

(3) a substantial likelihood exists that the person will not respond to a citation.

…
(c) Offenses Not Punishable by Incarceration. A citation must be issued for petty misdemeanors and misdemeanors not punishable by incarceration. If an arrest has been made, a citation must be issued in lieu of continued detention.”

Rule 6.01, Subd. 1, Minn. Rules of Crim. Pro., Pretrial Release, Release on Citation

Not punishable by incarceration: According to one court, “not punishable by incarceration” designates a petty misdemeanor for which jail time is never authorized, as opposed to a misdemeanor for which jail time, although not necessarily the norm, is always authorized and therefore always possible. fn1, State v. Beardemphl, 674 NW2d 430 (Minn. Court of Appeals 2004). On the other hand, Minnesota law defines a petty misdemeanor as “not a crime,” Minn. Stat. § 609.02, subd. 4a, and a misdemeanor as “a crime for which a sentence of not more than 90 days … may be imposed,” Minn. Stat. § 609.02, subd. 3. Since Rule 6.01, Subd. 1(c) says “for petty misdemeanors and misdemeanors” the rule distinguishes between the two. And a misdemeanor is always theoretically “punishable” by incarceration in Minnesota. So how can this wording possibly be reconciled?

In Minnesota some misdemeanors are not punishable by incarceration by court rule, de facto, even though arguably punishable by statute. Why? Minnesota payable offenses allow individuals to pay fines for petty misdemeanors and specific misdemeanors on the list without a court appearance, constituting a guilty plea. Those listed misdemeanors fit the definition of “misdemeanors not punishable by incarceration.” For those “payable offense” misdemeanors, the defendant has the agency and the right to avoid incarceration. Therefore they are not punishable by incarceration.

Statute supersedes court rule: An important issue in misdemeanor cases is that Minn. R. Crim. P. 6.01, subd. 1(a)(1)-(3) is superseded by statute. Minn. Stat. § 480.059, subd. 1 authorizes the Supreme Court to promulgate criminal rules that “regulate the pleadings, practice, procedure, and the forms thereof in criminal actions in all courts of this state[.]” Subdivision 7 provides a general rule that when a statute conflicts with a criminal rule, the statute shall “be of no force and effect.” However, subdivision 7 explicitly provides that certain statutes remain in full force and effect, including “(6) statutes which relate to extradition, detainers, and arrest, found in sections 629.01 to 629.404.”

The Court’s Criminal Rules “govern the procedure in prosecutions for felonies, gross misdemeanors, misdemeanors, and petty misdemeanors in the district courts in the State of Minnesota.” Minn. R. Crim. P. 1.01. The Criminal Rules are intended “to provide a just determination of criminal proceedings, and ensure a simple and fair procedure that eliminates unjustified expense and delay.” Minn. R. Crim. P. 1.02. Rule 6 addresses procedural issues regarding pretrial release. Rule 6.01, subd. 1 provides for an arresting officer to issue a citation in misdemeanor cases as quoted above.

So this rule applies after a warrantless misdemeanor arrest is made. This rule does not provide the standard for making a misdemeanor arrest, only the standard that permits the detention of an arrestee in lieu of citation and release. So the exceptions in Rule 6.01, subd. 1 cannot be used to justify a misdemeanor arrest. This exception merely authorizes the continued detention of Defendant in lieu of citation and release, and rests on the assumption that a lawful misdemeanor arrest has already been made.

The requirements of Minnesota Statutes Section 629.34 limit when arrests may be lawfully made without a warrant. Its conditions must be met or the arrest is illegal.

Probable Cause for Arrest

A probable cause determination requires the court to assess whether the facts and circumstances known to the officer would warrant a prudent person’s belief that an offense has been committed and that the accused committed it. The Minnesota Supreme Court summarized substantive law on cause for arrests:

“[P]robable cause for arrest exists where there is a reasonable ground for suspicion supported by circumstances sufficiently strong in themselves to warrant a cautious man in believing the accused to be guilty.”

State v. Fish, 159 NW2d 786, 790 (Minn. Supreme Court 1968)

The probable cause standard varies depending upon context such as probable to arrest, to support a charging document, to survive a pretrial challenge, etc. But probable cause requires more objective facts than the reasonable articulable suspicion required for a brief seizure, but less than the preponderance of the evidence or beyond a reasonable doubt standards.

Search Incident to Arrest

A lawful arrest justifies a full search of the person. United States v. Robinson, 414 U.S. 218 (US Supreme Court 1973).

“When police make a lawful arrest, they may search

the arrestee’s person and the area “within his immediate control” — construing that phrase to mean the area from within which he might gain possession of a weapon or destructible evidence.

Chimel v. California, 395 U.S. 752, 763 (1969). …

The facts support the district court’s determination that the search occurred beyond Fisher’s area of “immediate control” under Chimel.” 

State v. Fisher, 588 NW 2d 515 (Minn. Court of Appeals 1999)

As a result, if a search was illegal then evidence illegally obtained in a search incident should be suppressed. More on illegal searches:

Illegal Search | Fourth Amendment.

Statements After Illegal Arrest

If police get a confession or statement as the result of an unlawful arrest, it should be suppressed as illegal. More on suppression of statements obtained illegally:

Involuntary Statements

Miranda Rights & Confessions

Immediate Presentation to Judge, 36 Hour, 48 Hour Rules

For thousands of years laws have pushed police and prosecutors towards immediate judicial review of warrantless arrests where a person is held in custody. This body of law includes Constitutional law (the “supreme Law of the Land”), as well as Minnesota statutes and Minnesota court rules. One example is Minnesota Statutes § 629.401 “Delaying to Take Prisoner Before Judge” which says: “A peace officer or other person who willfully and wrongfully delays taking an arrested person before a judge having appropriate criminal jurisdiction is guilty of a gross misdemeanor.” But most of the cases rely on the U.S. Constitution and Minnesota Court rules, which we discuss below.

Rule 4.03, or the 48-hour rule, states that “[w]hen a person arrested without a warrant is not released under this rule or Rule 6, a judge must make a probable cause determination without unnecessary delay, and in any event within 48 hours from the time of the arrest, including the day of arrest, Saturdays, Sundays, and legal holidays.” Minn. R. Crim. P. 4.03, subd. 1.

Police violate the 48-hour rule by failing to obtain a judicial probable cause determination within 48 hours after his arrest. See Minn. R. Crim. P. 4.03, subd. 1. A “probable cause determination made later than 48 hours after arrest is unconstitutional unless the state can demonstrate the existence of a bona fide emergency or other extraordinary circumstance.” State v. Jackson, 472 NW2d 861, 863 (Minn. Supreme Court 1991); State v. Case, 412 N.W.2d 1, 4 (Minn. App. 1987) (refusing to vacate conviction due to passage of more than 36 hours between time of arrest and first appearance in court, when not prejudiced by the delay), review denied (Minn. Supreme Court 1987).

U.S. Constitution: A judicial determination of probable cause must be made within 48 hours of arrest including weekends, for persons arrested without a warrant. County of Riverside v. McLaughlin, 500 U.S. 44, 45 (US Supreme Court 1991).

The Minnesota Court of Appeals provides a concise summary of law on this topic:

“Detention following a warrantless arrest (as opposed to immediate release after a citation) has always included the right to prompt presentation before a judge or magistrate. See County of Riverside v. McLaughlin, 500 U.S. 44, 61-63 (1991) (Scalia, J., dissenting) (recounting caselaw documenting the centuries-old English and American requirement that post-arrest detention required presentment of the accused to a judge as soon as practical after the arrest to support ongoing detention). The right to presentment before a judge as the defendant begins a potentially extended period of pretrial incarceration is embodied in the Fourth Amendment. See Gerstein v. Pugh, 420 U.S. 103, 114 (1975) (recognizing that “the Fourth Amendment requires a judicial determination of probable cause as a prerequisite to extended restraint of liberty following arrest”). The Gerstein Court concluded that warrantless arrests require the determination of probable cause to be made “by a judicial officer … promptly after arrest.” Id. at 125.”

State v. Shimota, 875 NW2d 363 (Minn. Court of Appeals 2016)

Minnesota Rules of Criminal Procedure Rule 4.02, subdivision 5(1), the prompt appearance rule or the 36-hour rule, states that a person arrested without a warrant must “be brought before a judge without unnecessary delay, and not more than 36 hours after the arrest, exclusive of the day of arrest, Sundays, and legal holidays, or as soon as a judge is available.”

However, In State v. Waddell the Minnesota Supreme Court explains that the 36-hour rule is time-honored and important, particularly to avoid the coercive nature of custodial interrogation, pressure to confess and to expedite legal counsel safeguards. State v. Waddell, 655 N.W.2d 803, 811 (Minn. 2003). But, the courts do not automatically exclude confessions made after violation of the rule. State v. Wiberg, 296 NW 2d 388, 393 (Minn. Supreme Court 1980). Courts evaluate the prejudicial effect of the delay. Delay in arraignment should “weigh heavily” in any decision whether to suppress evidence. Id. at 393. Courts deciding whether evidence should be suppressed apply the nonexclusive factors in Wiberg including: 1) reliability of the evidence; 2) whether delay was intentional; 3) whether delay compounded effects of other police misconduct; and 4) length of the delay. Id. at 393.

Remedy: The prompt appearance rules have different purposes, histories, and remedies. One type of remedy is typically limited by time. A Petition for Writ of Habeas Corpus for immediate release, or a similar motion to the court, citing these laws can be moot (a matter no longer requiring a judicial decision after resolution of the underlying controversy) after the defendant has been released or brought before a judge. However, as the discussion above shows, sometimes a court will grant a remedy after those things occur.

An old legal maxim says “without a remedy, there is no right.” So the law sometimes identifies a legal “right,” but courts less often will provide a legal remedy, such as suppression of evidence or dismissal of charges. Or, judges may condition and limit those remedies to exceptional cases. And in reality, if a “right” is unenforceable it is merely an illusion.

Illegal Arrests and Fleeing, Resisting and Obstructing

An arrest by a police officer is the use or threatened use of force by the police officer within the context of an assertion of lawful authority to seize and intrude upon the liberty of a person. And such an attempt can be defeated by the targeted person fleeing, or by their resisting arresting or otherwise obstructing legal process.

And historically, we had every right to flee or resist an unlawful arrest. But today in Minnesota, though that legal right has been eroded, its unlawfulness can still be a defense to these crimes in some situations:

Fleeing Police vs Criminal Intent

Obstruction, Resisting Arrest

Question? Call Attorney Thomas Gallagher, 612 333-1500

If you have a question, or want to discuss your case, call Attorney Thomas Gallagher.

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