State v. Minneci

CourtCourt of Appeals of Oregon
DecidedApril 29, 2026
DocketA182877
StatusPublished

This text of State v. Minneci (State v. Minneci) is published on Counsel Stack Legal Research, covering Court of Appeals of Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Minneci, (Or. Ct. App. 2026).

Opinion

108 April 29, 2026 No. 341

IN THE COURT OF APPEALS OF THE STATE OF OREGON

STATE OF OREGON, Plaintiff-Respondent, v. ANTHONY ROSS MINNECI, aka Anthony Minneci, aka Anthony Ross Menneci, Defendant-Appellant. Jackson County Circuit Court 20CR62584, 21CR49154, 19CR78970, 19CR01196; A182877 (Control), A182878, A182879, A182880

Laura A. Cromwell, Judge. Submitted November 13, 2025. Ernest G. Lannet, Chief Defender, Criminal Appellate Section, and Sara F. Werboff, Deputy Public Defender, Oregon Public Defense Commission, filed the brief for appellant. Dan Rayfield, Attorney General, Benjamin Gutman, Solicitor General, and Peenesh Shah, Assistant Attorney General, filed the brief for respondent. Before Aoyagi, Presiding Judge, Egan, Judge, and Pagán, Judge. PAGÁN, J. Affirmed. Cite as 349 Or App 108 (2026) 109

PAGÀN, J. Defendant appeals his convictions, after a con- ditional guilty plea, of felon in possession of a firearm, ORS 166.270, and possession of a restricted firearm, ORS 166.272, challenging in a single assignment of error the trial court’s order denying his motion to suppress evidence seized in the execution of a search warrant.1 As explained below, we affirm. The relevant facts are not disputed. Police obtained a warrant to enter and search defendant’s home for evidence of reckless driving and attempting to elude a police officer. In the execution of that warrant, officers viewed drugs and weapons in plain view. Officers then obtained and executed a second warrant to search the home and defendant’s person for evidence of drug and weapon offenses, on which defen- dant’s challenged convictions are based. During litigation on a motion to suppress, it came to light that the copy of the warrant that the court had in its record as the “returned” copy of the first warrant (for a search for evidence of reckless driving and attempting to elude a police officer), i.e., the version on which defendant based his motion to suppress, was different from the ver- sion of the first warrant that the trial court found had been issued by the magistrate and executed and that the execut- ing officer had returned. Defendant argued to the trial court that the statutory scheme required that the warrant that was returned to the court must be the warrant that was issued and executed and that, because a different warrant was in the court’s possession as the “returned” warrant, the evidence must be suppressed. ORS 133.615, which governs the return of the war- rant, provides, in part: “(2) An officer who has executed a search warrant shall, as soon as is reasonably possible and in no event later than the date specified in the warrant, return the warrant

1 Defendant was convicted of a number of other offenses in a number of cases. On appeal, he challenges only the convictions after a conditional guilty plea of felon in possession of a firearm and possession of a restricted firearm in Jackson County Case Number 20CR62584. 110 State v. Minneci

to the issuing judge together with a signed list of things seized and setting forth the date and time of the search. “(3) Subject to the provisions of subsection (4) of this section, the issuing judge shall file the warrant and list returned to the judge, with the record of the proceedings on the application for the warrant made pursuant to ORS 133.555.” Defendant correctly pointed out that, under the plain text of ORS 133.615(2), the executing officer must return to the issuing magistrate the same warrant that has been exe- cuted. The magistrate who issued the warrant must then file with the court the warrant that was issued, a record of warrant proceedings, and a list of things seized. ORS 133.615(3). Defendant asserted that the “returned” warrant in the court’s possession is the version of the warrant on which the court’s evaluation of the motion to suppress must be based, that that version of the warrant was facially invalid, and that the evidence seized pursuant to that invalid war- rant must be suppressed. In defendant’s view, it was imma- terial, under the circumstances, whether the version of the warrant that was actually issued by the magistrate and executed was valid or not. The state responded that the court’s possession of a “returned” warrant that is different from the warrant that was actually issued, executed, and returned, was likely a ministerial error that did not invalidate the warrant that was actually issued and executed. The trial court agreed with the state. The court found that the warrant that was actually issued and executed was based on affidavits that had been presented to the magistrate who issued it. The court rejected defendant’s contentions that the warrant that had been issued and executed was invalid and that the “returned” warrant in the court’s possession was controlling. On appeal, defendant argues, “Viewed comprehen- sively, the warrant statutes impose a requirement that the executing officer and issuing judge obtain, serve, and keep a single version of the search warrant.” In defendant’s view, because the document on file with the court is different from the warrant that was issued and executed, the statutes have Cite as 349 Or App 108 (2026) 111

been violated, and the court erred in denying his motion to suppress. We conclude that the trial court did not err. It is undisputed that the warrant in the court’s possession as “returned” is different from the warrant that was issued by the magistrate and executed. We do not disagree with defendant’s reading of the statutes that, in the ordinary course, the warrant returned is the warrant that was issued and executed. But we conclude that a ministerial error in the “return” of the warrant does not require suppression of evidence that was seized based on a properly issued and exe- cuted warrant. Our conclusion is supported by State v. Ronniger, 7 Or App 447, 456, 492 P2d 298 (1971). In that case we rejected the defendant’s argument that the warrant was invalid because the items that were seized were retained in police custody and not returned to the magistrate who had issued the warrant, explaining: “[I]t is settled law that defects in the return of a search warrant are ministerial and are not grounds for invalidat- ing the search, at least where defendant is not prejudiced thereby.” (Citing State v. Cortman, 251 Or 566, 571, 446 P2d 681 (1968), cert den, 394 US 951 (1969) (failure of police to make a prompt inventory return does not invalidate a search)). Defendant does not assert that he suffered preju- dice because of the ministerial error in the return of the warrant. Defendant responds, however, that Ronniger, on which the state relies, is no longer good law, in light of the Supreme Court’s recent opinion in State v. Lee, 371 Or 200, 532 P3d 894 (2023), modified on recons, 373 Or 525, 568 P3d 139 (2025), in which the court held that granting a motion to suppress is the remedy for an “anticipatory” warrant issued in violation of ORS 133.545(6). The court explained in Lee that the remedy of suppression was authorized by ORS 133.673(1). 371 Or at 219.

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Related

State v. Cortman
446 P.2d 681 (Oregon Supreme Court, 1968)
State v. Ronniger
492 P.2d 298 (Court of Appeals of Oregon, 1971)
State v. Lee
532 P.3d 894 (Oregon Supreme Court, 2023)
State v. Lee
568 P.3d 139 (Oregon Supreme Court, 2025)
State v. Lee
373 Or. 525 (Oregon Supreme Court, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Minneci, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-minneci-orctapp-2026.