Indeed, it is this distinction that the Minnesota
Court of Appeals relied on to adopt a per se rule prohibiting all investigative vehicle stops for past misdemeanor offenses. In so holding, the court reasoned that the aggregate governmental interests that such stops would promote did not outweigh the severe interference with personal liberty that such stops implicate. This court was correct: the governmental interests in solving crimes and bringing offenders to justice that justified the Court’s extension of Terry in the Hensley decision do not support the further extension of Terry to stops for completed misdemeanors. Misdemeanors are, by definition, less serious offenses than felonies, and the public interest in bringing such offenders to justice is not high enough to outweigh the strong privacy interests implicated by Terry stops.