Minnesota Supreme Court’s State v. Bee: A dubious “public place” ruling

As a Pennsylvania lawyer, I’m skeptical of judicial overreach, especially when it muddies constitutional waters. The Minnesota Supreme Court’s recent decision in State v. Bee (filed February 19, 2025) is a case in point. It ruled that a vehicle’s interior on a public roadway is a “public place” under Minn. Stat. § 624.7181, subd. 1(c), upholding a gross misdemeanor charge for carrying a BB gun. For those of us in Pennsylvania, this isn’t binding—but it’s a warning shot worth heeding.

In Bee, a Ramsey County deputy stopped Kyaw Be Bee and found a BB gun under his driver’s seat. Charged under Minn. Stat. § 624.7181, subd. 2 (prohibiting carrying a BB gun “in a public place”), Bee saw the district court dismiss the case, deeming a private vehicle’s interior non-public. The court of appeals reversed and now the Minnesota Supreme Court has upheld the reversal.
Specifically, the Minnesota Supreme Court has held that “public place”—defined as government-controlled property (like roads) or private property “regularly and frequently open” to the public—unambiguously includes a vehicle’s interior on a public road.

The court’s logic? First, a statutory exemption (subd. 1(b)(5)) allows BB gun transport in vehicles if cased or permitted, implying that without such conditions, it’s illegal—thus, the interior must be public. Second, the statute’s exceptions (e.g., homes, land) are fixed real property, suggesting “public place” is geographic (the road), not spatial (the vehicle). This reasoning feels more like a stretch than a slam dunk.

Fourth Amendment Red Flags

Vehicles enjoy a reduced but real privacy expectation (California v. Carney, 471 U.S. 386, 1985), and searches require probable cause or a warrant absent exceptions (Carroll v. United States, 267 U.S. 132, 1925). Bee doesn’t directly gut this—it’s a statutory call, not a search ruling—but it’s troubling. Labeling a private vehicle’s interior “public” flirts with eroding that expectation, potentially inviting laxer search standards down the line. The court dodged this tension, focusing on legislative text over constitutional norms, which leaves a sour taste.

Not Our Problem—Yet

Fortunately, a Minnesota Supreme Court decision, regarding Minnesota State Law does not implicate Pennsylvanians or directly affect our Commonwealth. In fact, The PA Supreme Court in Commonwealth v. Alexander, 243 A.3d 177 (Pa. 2020) rejected the federal automobile exception. The federal exception (absent a warrant) required either probable cause OR exigent circumstances. Instead the PA Supreme Court opined that Article 1, Section 8 of the Pennsylvania Constitution requires (absent a warrant) BOTH probable cause and exigent circumstances to effect a vehicle search.

While Bee is not binding on Pennsylvania, this opinion demonstrates why one must pay close attention to what laws actually say. The Minnesota Supreme Court reasons their opinion is not constitutional or even search related in its nature and instead says they are simply ruling on the statute.

The language that law makers choose to use can and will be construed by courts to reach conclusions which legislators—and the general public—may never have expected.

If you have questions about Pennsylvania or Federal firearms laws, reach out to me at info@moorelegalcounsel.com or Jmoore@princelaw.com

*This article references information previously reported by https://www.ammoland.com/2025/02/mn-supreme-court-public-place-includes-interior-of-your-car/

**The Court’s opinion is available at: Click Here (Opens a PDF)