Stoner v. California
376 U.S. 483 (1964)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A hotel guest's Fourth Amendment protection against unreasonable searches and seizures cannot be waived by the consent of a hotel employee, such as a desk clerk. The right to be free from a warrantless search of one's hotel room is a personal right that can only be waived by the guest or their agent.
Facts:
- On October 25, 1960, two men robbed the Budget Town Food Market in Monrovia, California; one was described as wearing a grey jacket and horn-rimmed glasses and carrying a gun.
- Police found a checkbook belonging to Joey L. Stoner in a nearby parking lot.
- Check stubs led police to the Mayfair Hotel, where they learned Stoner was a guest in Room 404.
- Eyewitnesses to the robbery identified a photograph of Stoner as looking like the gunman.
- On October 27, without a warrant, police went to the hotel and the night clerk confirmed Stoner was a guest but was currently out.
- At the officers' request, the night clerk gave them permission to enter, used a key to unlock the door to Room 404, and let them into Stoner's room.
- Inside the room, police conducted a thorough search and found a .45-caliber pistol, a grey jacket, and horn-rimmed glasses.
- Two days later, police arrested Stoner in Las Vegas, Nevada.
Procedural Posture:
- Joey L. Stoner was tried by a jury in the Superior Court of Los Angeles County, California, for armed robbery.
- Over Stoner's objection, evidence seized from his hotel room was admitted at trial.
- The jury convicted Stoner.
- Stoner appealed his conviction to a California District Court of Appeal.
- The District Court of Appeal affirmed the conviction, finding the search was justified as incident to a lawful arrest.
- The Supreme Court of California denied further review.
- The U.S. Supreme Court granted certiorari, limited to the question of whether the evidence was obtained by an unlawful search and seizure.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a hotel clerk's consent to a warrantless search of a guest's room waive the guest's Fourth Amendment right against unreasonable searches and seizures?
Opinions:
Majority - Mr. Justice Stewart
No. A hotel employee does not have the authority to consent to a warrantless search of a guest's room, and such a search violates the guest's Fourth Amendment rights. The right against unreasonable searches is a personal right belonging to the petitioner, not the hotel or its employees, and only the petitioner can waive it. The Court rejected the argument that the police reasonably believed the clerk had 'apparent authority,' stating that constitutional rights are not to be eroded by strained applications of agency law. Citing precedent from Lustig and Jeffers, the Court affirmed that a hotel guest is entitled to the same constitutional protection as a tenant in a house. This protection would be rendered meaningless if it depended on the 'unfettered discretion' of a hotel employee. The search was also not a valid search incident to arrest, as it was neither contemporaneous with nor in the vicinity of the arrest, which occurred two days later in a different state.
Concurring in part and dissenting in part - Mr. Justice Harlan
No. While fully agreeing with the majority's conclusion that the search was unconstitutional, the case should not be reversed outright. Instead, the judgment should be vacated and the case remanded to the California courts. This would allow the state court the opportunity to determine, in the first instance, whether the admission of the illegally seized evidence constituted harmless error.
Analysis:
This case solidifies the principle that a hotel room is a constitutionally protected area for Fourth Amendment purposes, treating it with the same sanctity as a private home. By rejecting the 'apparent authority' doctrine in this context, the Court reinforced that Fourth Amendment rights are personal and cannot be waived by third parties who merely have a property interest or access for limited purposes, such as a landlord or hotel clerk. This decision significantly limits the ability of law enforcement to conduct warrantless searches of transient lodgings by seeking consent from proprietors, thereby strengthening privacy protections for individuals away from home. It sets a clear precedent that consent must come from the individual whose rights are at stake or their specifically authorized agent.
Unlock the full brief for Stoner v. California