Minnesota v. Olson
495 U.S. 91 (1990)
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Rule of Law:
A person's status as an overnight guest in another's home is sufficient to establish a legitimate expectation of privacy protected by the Fourth Amendment's prohibition against warrantless, nonconsensual entry and arrest.
Facts:
- Following a robbery and murder at a gas station, police identified Joseph Ecker as the gunman and Robert Olson as the suspected getaway driver.
- Ecker was apprehended, but Olson escaped.
- An informant told police that Olson was staying at a duplex residence belonging to Louanne and Julie Bergstrom.
- Olson had permission from the Bergstroms to stay at their home, where he spent the night on the floor and kept a change of clothes.
- A neighbor in the lower unit of the duplex, Helen Niederhoffer, called police to inform them that Olson had returned to the Bergstroms' upper unit.
- Police surrounded the duplex and telephoned inside, telling Julie Bergstrom that Olson should come out.
- After hearing a male voice say, "tell them I left," police, without a warrant or permission, entered the upper unit with weapons drawn.
- Police found Olson hiding in a closet and arrested him.
Procedural Posture:
- In the Hennepin County trial court, Robert Olson filed a motion to suppress his inculpatory statement made after his arrest.
- The trial court denied the motion to suppress.
- The statement was admitted into evidence, and a jury convicted Olson on charges of murder, armed robbery, and assault.
- Olson (as appellant) appealed his conviction to the Minnesota Supreme Court.
- The Minnesota Supreme Court (the state's highest court) reversed the conviction, holding that Olson had a sufficient privacy interest to challenge the warrantless arrest and that no exigent circumstances justified the police entry.
- The State of Minnesota (as petitioner) petitioned for, and was granted, a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does a person's status as an overnight guest in another's home give them a reasonable expectation of privacy protected by the Fourth Amendment, thereby making a warrantless, nonconsensual police entry and arrest of that person in the home unconstitutional absent exigent circumstances?
Opinions:
Majority - Justice White
Yes. An overnight guest has a reasonable expectation of privacy in the host's home that is protected by the Fourth Amendment, rendering a warrantless, nonconsensual entry for the purpose of arrest unconstitutional. The Court rejected the State's proposed multi-factor test for what constitutes a 'home,' holding instead that Olson's status as an overnight guest is 'alone enough' to show he had a legitimate expectation of privacy. This expectation is rooted in longstanding social customs and understandings that society recognizes as reasonable; a guest seeks shelter in a home for privacy and security, especially when asleep and vulnerable. Citing the factual holding of Jones v. United States, the court affirmed that one can have a legally sufficient interest in a place other than one's own home. The Court also deferred to the Minnesota Supreme Court's finding that no exigent circumstances—such as hot pursuit, risk of escape, or danger to others—existed to justify the warrantless entry, as police had the house surrounded and knew Olson was not the primary murder suspect.
Concurring - Justice Stevens
Yes. Justice Stevens joined the Court's opinion but wrote separately to emphasize that state courts are free to grant litigants more protection and broader standing to raise federal constitutional questions than federal courts would. He cautioned that the Supreme Court should not frequently review cases where a state court has chosen to impose higher standards on its own law enforcement officials, as it has no power to prevent state courts from doing so.
Concurring - Justice Kennedy
Yes. Justice Kennedy joined the majority opinion with the specific understanding that the Court's agreement with the lower court on the exigent circumstances issue was a matter of deference to the state court's fact-specific application of the test, not a broad endorsement of that particular application.
Analysis:
This decision significantly clarified Fourth Amendment standing by establishing a bright-line rule for overnight guests. It rejected a complex, fact-intensive inquiry into a person's connection to a premises, simplifying the analysis for future cases. By extending the protections of Payton v. New York to overnight guests, the Court reinforced the principle that the Fourth Amendment protects 'people, not places,' and that the sanctity of a home from warrantless intrusion extends to those temporarily but legitimately residing there. This precedent makes it easier for defendants who are not owners or tenants to challenge warrantless searches and seizures in a host's home.
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