The Fourth Amendment to the United States Constitution protects citizens from unreasonable searches and seizures of their persons or property. See U.S. Const., amend. IV. The exclusionary rule prohibits the use of evidence obtained in violation of the Fourth Amendment. See United States v. Calandra, 414 U.S. 338, 347 (1974). However, the exclusionary rule does not apply to all proceedings or against all persons and is generally restricted to areas in which the goal of deterring unlawful police conduct is "most efficaciously served." Id. at 348. In determining whether the exclusionary rule applies, the U.S. Supreme Court has developed a balancing test whereby courts weigh the likely social benefits of excluding unlawfully obtained evidence against the possible costs. See INS v. Lopez‑Mendoza, 468 U.S. 1032, 1041 (1984).
Typically, the exclusionary rule has been confined to cases in which the state seeks to use illegally seized evidence to criminally prosecute an individual who experienced an unlawful search. See Calandra, 414 U.S. at 347; e.g., id. at 354. The exclusionary rule is occasionally applied outside of a pure criminal proceeding, however. For instance, the Minnesota Supreme Court has held that the exclusionary rule applies to a civil forfeiture action, see Garcia‑Mendoza v. 2003 Chevy Tahoe, 852 N.W.2d 659, 667 (Minn. 2014), as well as a civil implied‑consent proceeding, see Ascher v. Comm'r of Pub. Safety, 527 N.W.2d 122, 125 (Minn. App. 1995), review denied (Minn. Mar. 21, 1995); see also State v. Lemmer, 736 N.W.2d 650, 654 (Minn. 2007) (revocation of a driver's license after a DWI arrest).