Bounds v. Commissioner of Public Safety

SUMMARY OPINION

HUSPENI, Judge.

FACTS

The facts relevant to this appeal are contained in Bounds v. Commissioner of Public Safety, 353 N.W.2d 659 (Minn.Ct.App.1984) {Bounds I). In Bounds I, this court held that, in the absence of a fresh pursuit, a peace officer outside his jurisdiction has the authority of a private citizen, but may not administer post-D.W.I. arrest procedures. The Commissioner of Public Safety petitioned the Minnesota Supreme Court for review of this decision, and the supreme court remanded the matter to us for reconsideration in light of its subsequent opinion in Windschitl v.…