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Law School Case Brief

Minnesota v. Olson - 495 U.S. 91, 110 S. Ct. 1684 (1990)

Rule:

An individual's status as an overnight guest in another person's home is alone enough to show that he had an expectation of privacy in the home that society is prepared to recognize as reasonable.

Facts:

Following an armed robbery police officers captured a man later identified as the lone gunman, recovered the murder weapon, and discovered leads suggesting that the driver of the getaway car was staying in a duplex, which unit was the residence of two women. Three or four police squads surrounded the building, and the detective in charge telephoned the residence and told one of the women that the suspected driver should come out. When the detective heard a male voice say "Tell them I left," he ordered the police to enter the residence, which they did without seeking permission and with weapons drawn. The police found the suspect hiding in a closet and arrested him. Less than an hour later, the suspect made an inculpatory statement at police headquarters. A Minnesota trial court denied the suspect's motion to suppress the statement, and the statement was admitted into evidence at the suspect's trial, which resulted in his conviction for murder, armed robbery, and assault. On appeal, the Supreme Court of Minnesota reversed and remanded for a new trial, as the court held that (1) the suspect had a sufficient interest in the women's home to challenge the legality of his warrantless arrest there, given evidence that he had had permission to stay there for an indefinite period and the right to admit or exclude visitors; (2) the arrest was illegal because there were no exigent circumstances to justify a warrantless entry. Petitioner, state of Minnesota, sought review of the order from the Supreme Court of Minnesota, which reversed defendant's conviction for first-degree murder, armed robbery, and second-degree assault and remanded the case for a new trial.

Issue:

Did the arrest violate Olson's Fourth Amendment rights?

Answer:

Yes

Conclusion:

On review, the Court held that defendant, as an overnight guest, had a reasonable expectation of privacy in his host's home. The Court held that the expectation was rooted in understandings that were recognized and permitted by society, it was legitimate, and that defendant could have claimed the protection of U.S. Const. amend. IV. The Court held that the state supreme court correctly applied the standard in determining whether exigent circumstances existed in the officers' warrantless entry of the home. The Court affirmed the order from the state supreme court.

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