Minnesota Bureau of Criminal Apprehension v. Mullin
Overview
Overview
The Minnesota Bureau of Criminal Apprehension and Hennepin County Attorney's Office sued the Department of Homeland Security over the Department's actions to deny state and local law enforcement from access evidence relevant to the shooting of a man by a federal immigration officer on January 24.
The Issue
Issue
Whether the Department of Homeland Security may withhold evidence and obstruct state law enforcement's access to materials relevant to a shooting incident involving a federal immigration officer.
The Rules
Rule
States retain concurrent jurisdiction to investigate crimes occurring within their borders. Federal agencies cannot unilaterally deny state law enforcement reasonable access to evidence material to state investigations absent clear statutory authority, valid privilege, or demonstrable national security concerns. Federalism principles limit federal executive power to obstruct legitimate state law enforcement activities.
The Application
Analysis
The DHS denied the Minnesota Bureau of Criminal Apprehension and Hennepin County Attorney's Office access to evidence from the January 24 shooting incident involving a federal immigration officer. This blanket denial prevented Minnesota state authorities from conducting a parallel investigation into the incident and conducting independent fact-finding within their jurisdiction.
The Conclusion
On February 2, 2026, the court dissolved the temporary restraining order it had granted on January 24 and denied the plaintiffs' request for further injunctive relief without prejudice, entering judgment for the defendants. The Minnesota Bureau of Criminal Apprehension and the Hennepin County Attorney's Office then voluntarily dismissed the case without prejudice on March 24, 2026, and the docket was terminated the following day. No settlement was reached.
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